Jack's Maintenance Contractors, Inc. v. Commissioner
United States Tax Court
A, an individual, incorporated his sole proprietorship as C corporation (petitioner). As C's president and sole shareholder, A made all management decisions and was solely responsible for C's acquisition of new business. Following C's incorporation, A (and his wife) were indicated for criminal tax violations and charged with having failed to include certain receipts of the sole proprietorship as business income on their joint returns.
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A, an individual, incorporated his sole proprietorship as C corporation (petitioner). As C's president and sole shareholder, A made all management decisions and was solely responsible for C's acquisition of new business. Following C's incorporation, A (and his wife) were indicated for criminal tax violations and charged with having failed to include certain receipts of the sole proprietorship as business income on their joint returns. C paid A's legal fees in connection with the criminal tax case. Held: C may deduct the legal fees it paid for A's defense under sec. 162(a), I.R.C. 1954. Lohrke…
1Opinion of the Court
JACK'S MAINTENANCE CONTRACTORS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jack's Maintenance Contractors, Inc. v. Commissioner
Docket No. 11114-79.
United States Tax Court
T.C. Memo 1981-349; 1981 Tax Ct. Memo LEXIS 393; 42 T.C.M. (CCH) 330; T.C.M. (RIA) 81349;
July 6, 1981
A, an individual, incorporated his sole proprietorship as C corporation (petitioner). As C's president and sole shareholder, A made all management decisions and was solely responsible for C's acquisition of new business. Following C's incorporation, A (and his wife) were indicated for criminal tax…
2Cases cited32 opinions
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- Kornhauser v. United StatesSupreme Court of the United States · 1928
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