Silverton v. Commissioner
United States Tax Court
Petitioner was the owner of a law firm that provided legal services to union groups and their members, church groups and their members, and ethnic groups, mostly on a contingent-fee basis. Petitioner was incarcerated in 1972 and sold the business. Held: 1. Case-preparation and litigation costs advanced by petitioner and recoverable only from the proceeds of suit or settlement were not deductible by petitioner in the year advanced unless the case was closed out in that year.
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Petitioner was the owner of a law firm that provided legal services to union groups and their members, church groups and their members, and ethnic groups, mostly on a contingent-fee basis. Petitioner was incarcerated in 1972 and sold the business. Held: 1. Case-preparation and litigation costs advanced by petitioner and recoverable only from the proceeds of suit or settlement were not deductible by petitioner in the year advanced unless the case was closed out in that year. Canelo v. Commissioner,53 T.C. 217 (1969), and Herrick v. Commissioner,63 T.C. 562 (1975), followed. 2. Amounts of…
1Opinion of the Court
RONALD R. SILVERTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
RONALD R. SILVERTON and B. SILVERTON v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Silverton v. Commissioner
Docket Nos. 8905-72, 8906-72, 8907-72, 7799-75.
United States Tax Court
T.C. Memo 1977-198; 1977 Tax Ct. Memo LEXIS 242; 36 T.C.M. (CCH) 817; T.C.M. (RIA) 770198;
June 28, 1977, Filed
Petitioner was the owner of a law firm that provided legal services to union groups and their members, church groups and their members, and ethnic groups, mostly on a contingent-fee basis. Petitioner was incarcerated in 1972 and…
2Cases cited43 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Crane v. CommissionerSupreme Court of the United States · 1947
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
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3Cited by1 opinion
- Boccardo v. United StatesUnited States Court of Claims · 1987