Legal Opinion
Estate of Joseph P. Morgan, Deceased and Margaret Koehler Morgan, Surviving Spouse v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 22, 1964No. 19746_1PublishedCited by 33 opinions
1Opinion of the Court
GEWIN, Circuit Judge.
The controversy presented by this; case involves the deductibility of certain expenses 1 2for the years 1956 and 1957 arising out of litigation. The taxpayers 2 deducted the expenses in their 1956 and 1957 income tax returns, and contend that they were authorized to do so under Section 162 or Section 212, Internal Revenue Code of 1954. The Com missioner disallowed the deductions. The Tax Court prorated the amount taxpayers expended in the litigation between defense of income and defense of title. 3 The Government contends that the decisions of the Tax Court are correct in…
2Cases cited23 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
- JONES'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
- Louisiana Land & Exploration Co. v. CommissionerUnited States Tax Court · 1946
18 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Robinson v. CommissionerUnited States Tax Court · 1994
- Boagni v. CommissionerUnited States Tax Court · 1973
- Reed v. CommissionerUnited States Tax Court · 1970
- Rafter v. CommissionerUnited States Tax Court · 1973
28 more not listed; retrieve them via the Exa API.