Legal Opinion

Farnsworth v. Commissioner

United States Tax Court

Decided March 21, 1958No. Docket Nos. 60596, 64736Published

1. Payments by petitioner of State unincorporated business taxes, personal income taxes, and interest thereon, allocable to his former partners, and for which he was not ultimately liable, held, not deductible by him as taxes paid, as ordinary and necessary business expense, or as losses in a transaction entered into for profit. 2. Payments by petitioner for legal services in connection with the foregoing, coupled with claims against himself and penalties thereon, held, on…

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1. Payments by petitioner of State unincorporated business taxes, personal income taxes, and interest thereon, allocable to his former partners, and for which he was not ultimately liable, held, not deductible by him as taxes paid, as ordinary and necessary business expense, or as losses in a transaction entered into for profit. 2. Payments by petitioner for legal services in connection with the foregoing, coupled with claims against himself and penalties thereon, held, on the facts, deductible in full.

1Opinion of the Court

Daniel W. Farnsworth and Gertrude A. Farnsworth, His Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent

Farnsworth v. Commissioner

Docket Nos. 60596, 64736

United States Tax Court

29 T.C. 1131; 1958 U.S. Tax Ct. LEXIS 230;

March 21, 1958, Filed

Decisions will be entered under Rule 50.

1. Payments by petitioner of State unincorporated business taxes, personal income taxes, and interest thereon, allocable to his former partners, and for which he was not ultimately liable, held, not deductible by him as taxes paid, as ordinary and necessary business expense, or as losses in a…

2Cases cited18 opinions

  1. Magruder v. SuppleeSupreme Court of the United States · 1942
  2. Podems v. CommissionerUnited States Tax Court · 1955
  3. Helvering v. FitchSupreme Court of the United States · 1940
  4. Helvering v. LeonardSupreme Court of the United States · 1940
  5. Towers v. CommissionerUnited States Tax Court · 1955

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