Legal Opinion
Mills Estate, Inc. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Mills Estate, Inc
Court of Appeals for the Second Circuit
Decided August 5, 1953No. 22430_1PublishedCited by 41 opinions
1Opinion of the Court
CHASE, Circuit Judge.
Both the Commissioner and the taxpayer have petitioned to review a decision of the Tax Court redetermining the deficiencies here questioned.
A deduction of the amount of fees and expenses paid in 1946 to attorneys was claimed under section 23(a) (1) (A) I.R. C., 26 U.S.C.A. § 23(a) (1) (A), as an ordinary and necessary expense paid during the taxable year in carrying on the taxpayer’s trade or business. It was disallowed by the Commissioner. The Tax Court, allowing one-half as an expense attributable to the cost of carrying out a partial liquidation and disallowing the…
2Cases cited16 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. Estate of BedfordSupreme Court of the United States · 1945
11 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Gravois Planing Mill Company, Charles A. And Florence Beckemeier v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Standard Linen Service, Inc. v. CommissionerUnited States Tax Court · 1959
36 more not listed; retrieve them via the Exa API.