Legal Opinion

Safety Tube Corp. v. Commissioner of Internal Rev.

Court of Appeals for the Sixth Circuit

Decided June 1, 1948No. 10614PublishedCited by 69 opinions

1Opinion of the Court

ALLEN, Circuit Judge.

This is a petition to review a decision of the Tax Court of the United States which sustained a determination of the Commissioner finding deficiencies in income tax of $1,138.23 and in personal holding company surtax of $9,221.34. An item of 25% surtax penalty in the amount of $2,305.34 was not sustained by the Tax Court, and is not involved.

The principal question arises out of the payment of $8,107.35, expenses of litigation, which was claimed as a deduction for the year 1940, upon the ground that it constituted an ordinary and necessary business expense. The Tax Court…

2Cases cited10 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Kornhauser v. United StatesSupreme Court of the United States · 1928
  3. JONES'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
  4. Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
  5. Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946

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3Cited by69 opinions

  1. Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
  2. Duttenhofer v. CommissionerUnited States Tax Court · 1967
  3. Kasey v. CommissionerUnited States Tax Court · 1970
  4. Sanders v. CommissionerUnited States Tax Court · 1954
  5. Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960

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