Farnsworth v. Commissioner
United States Tax Court
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
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Podems v. CommissionerUnited States Tax Court · 1955
- Helvering v. FitchSupreme Court of the United States · 1940
- Helvering v. LeonardSupreme Court of the United States · 1940
- Towers v. CommissionerUnited States Tax Court · 1955
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