Ruoff v. Commissioner
United States Tax Court
Attorney expenses incurred to contest Alien Property Custodian's seizure of petitioner's income-producing property, held, comparable to costs of defense of title and, as such, capital expenditures not deductible under section 23 (a) (2), I. R. C. 1939.
1Opinion of the Court
Respondent determined a deficiency of $42,443.24 in petitioners’ income tax for 1953. The only remaining issue is whether expenses of litigation in connection with, a suit to recover property “vested” by the Attorney General, under authority of the Trading With the Enemy Act, are deductible in 1953 when paid.
FINDINGS OF FACT.
All the facts are stipulated and they are hereby so found. Madeleine duPont Ruoff, hereafter refererd to as petitioner, and Hermann F. Ruoff, her husband, are citizens of the United States, residing at Mahwah, New Jersey. They filed their joint Federal income tax return…
Also in this document: Dissent.
2Cases cited30 opinions
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Murphy Oil Co. v. BurnetSupreme Court of the United States · 1932
- Lykes v. United StatesSupreme Court of the United States · 1952
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
25 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970
- Manufacturers Hanover Trust Company, as Trustee Under Indenture Dated November 15, 1927, Made by Henry H. Rogers, Deceased v. The United StatesUnited States Court of Claims · 1963
- Hermann F. And Madeleine Dupont Ruoff v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
- Madden v. CommissionerUnited States Tax Court · 1972
23 more not listed; retrieve them via the Exa API.