Legal Opinion
Heller v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 27, 1945No. 10679PublishedCited by 52 opinions
1Opinion of the Court
GARRECHT, Circuit Judge.
On order of this court, the proceedings on the petition of Walter S. Heller, taxpayer, and the petition of the Commissioner of Internal Revenue for review of the decision of the Tax Court are consolidated.
The question raised by the petition of the Commissioner of Internal Revenue is whether attorney’s fees paid by the taxpayer in connection with litigation for the cash value of shares of stock were allowable as a deduction from gross income. The Tax Court found they were.
The Commissioner contends these fees were incurred in a matter pertaining to assets of a purely…
2Cases cited1 opinion
- Dobson v. CommissionerSupreme Court of the United States · 1944
3Cited by52 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Dwight A. Ward v. Commissioner of Internal Revenue, Hanna P. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
- E. W. Brown, Jr. And Gladys Slade Brown v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1954
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