Cochrane v. Commissioner
United States Board of Tax Appeals
1. Held that numerous expenditures made by petitioner in a professional capacity as a lawyer on behalf of his clients are not deductible as ordinary and necessary business expenses of petitioner for the year in which the expenditures were made.
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1. Held that numerous expenditures made by petitioner in a professional capacity as a lawyer on behalf of his clients are not deductible as ordinary and necessary business expenses of petitioner for the year in which the expenditures were made. Held, further, that amounts paid petitioner in the following year as reimbursement for such expenditures did not constitute income to petitioner in such year and should be excluded from income reported for that year. 2. An amount paid by petitioner to reimburse another of his clients for losses sustained by such client, due to petitioner's error in…
1Opinion of the Court
*207OPINION.
McMahon:
The petitioner, an attorney at law, claims that he is entitled to a deduction in the amount of $5,000 from his gross income for 1923 as ordinary and necessary business expense incurred and paid by him in obtaining a divorce for the daughter of one of his clients. In 1924 petitioner presented his bill to his. client for $10,000, representing his fee of $5,000 and expenditures incurred in the amount of $5,000. In that year petitioner returned the full amount of $1Q,000 as income, but claimed no deductions on account of expenditures made in connection with obtaining the divorce.…
2Cited by35 opinions
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- Canelo v. CommissionerUnited States Tax Court · 1969
- Reginald G. Hearn and Mary L. Hearn, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Hearn v. CommissionerUnited States Tax Court · 1961
- Smith v. CommissionerUnited States Tax Court · 1970
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