Legal Opinion

Cobb v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided April 4, 1949No. 10759PublishedCited by 28 opinions

1Opinion of the Court

MARTIN, Circuit Judge.

The question presented by this petition for review is whether, in the circumstances of the case, the petitioner may deduct from his gross income attorneys’ fees paid by him in the taxable year for professional services and advice in relation to a controversy concerning the amount of his liability for gift taxes. The Tax Court of the United States, three judges dissenting, held that such attorneys’ fees are not deductible by petitioner under section 23(a) (2) of the Internal Revenue Code, 26 U.S.C.A. § 23 (a) (2). No appellate court of the United States has yet decided…

2Cases cited6 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Kornhauser v. United StatesSupreme Court of the United States · 1928
  3. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  4. Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
  5. Stoddard v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945

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

3Cited by28 opinions

  1. Luman v. CommissionerUnited States Tax Court · 1982
  2. Lykes v. United StatesSupreme Court of the United States · 1952
  3. Professional Services v. CommissionerUnited States Tax Court · 1982
  4. Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  5. Epp v. CommissionerUnited States Tax Court · 1982

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

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