Legal Opinion

Houlihan v. Commissioner

United States Tax Court

Decided August 13, 1980No. Docket No. 426-79Unpublished

Held, petitioner is not entitled to a deduction under sec. 215, I.R.C. 1954, for payments made to his wife pursuant to an oral agreement; held further, petitioner is not entitled to file as a head of household for 1976; held further, petitioner is not entitled to a theft loss deduction in excess of the amount allowed by respondent.

1Opinion of the Court

ARTHUR HOULIHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Houlihan v. Commissioner

Docket No. 426-79.

United States Tax Court

T.C. Memo 1980-312; 1980 Tax Ct. Memo LEXIS 270; 40 T.C.M. (CCH) 965; T.C.M. (RIA) 80312;

August 13, 1980, Filed

Held, petitioner is not entitled to a deduction under sec. 215, I.R.C. 1954, for payments made to his wife pursuant to an oral agreement; held further, petitioner is not entitled to file as a head of household for 1976; held further, petitioner is not entitled to a theft loss deduction in excess of the amount allowed by respondent.

Arthur…

2Cases cited6 opinions

  1. Burnet v. HoustonSupreme Court of the United States · 1931
  2. Helvering v. OwensSupreme Court of the United States · 1939
  3. Millsap v. CommissionerUnited States Tax Court · 1966
  4. I. Hal Millsap, Jr., and Frances Millsap v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1968
  5. Herring v. CommissionerUnited States Tax Court · 1976

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