Legal Opinion

Home Trust Co. v. Commissioner of Internal Revenue

Court of Appeals for the Eighth Circuit

Decided May 11, 1933No. 9420PublishedCited by 27 opinions

1Opinion of the Court

KENYON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals entered May 29, 1931. The Home Trust Company and the Home Safe Deposit Company, petitioners, are affiliated companies, and filed consolidated returns for 1923 and 1924. The matter was dealt with by the Board as if only one petitioner were involved, and we shall follow for convenience that procedure. Only one question is in dispute, to wit: Whether $75,000 paid by the Home Trust Company in 1924 to secure immediate possession of a leasehold from a sublessee is an “ordinary and necessary” expense…

2Cases cited11 opinions

  1. Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
  2. Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
  3. Simmons Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1929
  4. Young v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1932
  5. Central Bank Block Ass'n v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1932

6 more not listed; retrieve them via the Exa API.

3Cited by27 opinions

  1. The Crosley Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1956
  2. Commissioner of Internal Revenue v. Boylston Market Ass'nCourt of Appeals for the First Circuit · 1942
  3. Commissioner of Internal Revenue v. Boston Elevated Ry. CoCourt of Appeals for the First Circuit · 1952
  4. Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
  5. Boston Elevated Railway Co. v. CommissionerUnited States Tax Court · 1951

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