Legal Opinion

Daniel S. W. Kelly v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided January 4, 1956No. 11491_1PublishedCited by 55 opinions

1Opinion of the Court

DUFFY, Chief Judge.

On his federal income tax return for 1947 taxpayer claimed as deductions “lawyer’s fees and expenses, $2231.10” and “safe deposit boxes, $9.60.” The Commissioner disallowed these claims. The Tax Court held 23 T.C. 682 that taxpayer was entitled to deduct only $600 which sum it calculated was the reasonable proportion of the total fees and expenses which taxpayer incurred in the recovery of interest and rental income. The Court also held the expenditure of $9.60 for safety deposit rental was proper. The balance of the claimed deductions was disallowed.

Taxpayer is a resident…

2Cases cited11 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  3. Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
  4. E. W. Brown, Jr. And Gladys Slade Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
  5. Helvering v. StormfeltzCourt of Appeals for the Eighth Circuit · 1944

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3Cited by55 opinions

  1. Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  2. Boagni v. CommissionerUnited States Tax Court · 1973
  3. Estate of Upshaw v. CommissionerCourt of Appeals for the Seventh Circuit · 1969
  4. Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
  5. Spector v. CommissionerUnited States Tax Court · 1979

50 more not listed; retrieve them via the Exa API.

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