Miller v. Commissioner
United States Tax Court
Held, the administration of the Estate of Addison Miller was unduly prolonged beyond the end of 1955 and consequently the income of said estate for 1956 and part of 1957 was properly includable in petitioner's income for 1956 and 1957. Held, further, petitioner is not entitled to a deduction for the loss of purported goodwill in 1958 as a result of the cessation of business operations in that year.
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Held, the administration of the Estate of Addison Miller was unduly prolonged beyond the end of 1955 and consequently the income of said estate for 1956 and part of 1957 was properly includable in petitioner's income for 1956 and 1957. Held, further, petitioner is not entitled to a deduction for the loss of purported goodwill in 1958 as a result of the cessation of business operations in that year. Held, further, petitioner is not entitled to a deduction for club dues as ordinary and necessary business expenses.
1Opinion of the Court
A. T. Miller and Estate of Eleanor A. Miller, Deceased, First Trust Company of Saint Paul, Special and General Administrator, Petitioners, v. Commissioner of Internal Revenue, Respondent. A. T. Miller and Estate of Eleanor A. Miller, Deceased, First Trust Company of Saint Paul, Administrator, Petitioners, v. Commissioner of Internal Revenue, Respondent
Miller v. Commissioner
Docket Nos. 87484, 91439
United States Tax Court
39 T.C. 940; 1963 U.S. Tax Ct. LEXIS 177;
March 20, 1963, Filed
Decisions will be entered under Rule 50.
Held, the administration of the Estate of Addison Miller was unduly…
2Cases cited14 opinions
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- Williams v. CommissionerUnited States Tax Court · 1951
- Chick v. CommissionerUnited States Tax Court · 1946
- Chick v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Carty v. CommissionerUnited States Tax Court · 1962
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