Legal Opinion
Cagle v. Commissioner
Court of Appeals for the Fifth Circuit
Decided September 22, 1976No. Nos. 75-1722 and 75-1723PublishedCited by 26 opinions
1Opinion of the Court
SIMPSON, Circuit Judge:
Taxpayers appeal from a ruling of the Tax Court upholding the Commissioner of Internal Revenue’s finding of a deficiency in the federal income taxes for appellants. The findings of fact and opinion of the Tax Court are reported at 63 T.C. 86.
The sole issue presented on appeal is whether $90,000 paid by a partnership to its managing partner was a deductible expense under Section 707(c) of the Internal Revenue Code of 1954, Title 26, U.S.C., Section 707(c),1 or a capital expenditure under Section 263(a) of the Code, and hence not deductible as an ordinary and necessary…
2Cases cited27 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Enoch v. CommissionerUnited States Tax Court · 1972
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
22 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Goodwin v. CommissionerUnited States Tax Court · 1980
- Luther R. Patton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Ellis Banking Corporation v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1982
- Blitzer v. United StatesUnited States Court of Claims · 1982
- United States v. Ronald H. PachecoCourt of Appeals for the Ninth Circuit · 1990
21 more not listed; retrieve them via the Exa API.