Levinstein v. Commissioner
United States Board of Tax Appeals
During the year 1922 petitioner paid $11,200 which had been levied against him under the provisions of section 608 of the Revenue Act of 1918. He also paid attorney's fees during that year amounting to $10,000 and paid an additional fee during the year 1923 amounting to $3,000. Of the attorney's fees $5,000 was paid for services rendered in connection with a compromise of the levy made under the provisions of section 608 of the Revenue Act of 1918. The balance of the…
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During the year 1922 petitioner paid $11,200 which had been levied against him under the provisions of section 608 of the Revenue Act of 1918. He also paid attorney's fees during that year amounting to $10,000 and paid an additional fee during the year 1923 amounting to $3,000. Of the attorney's fees $5,000 was paid for services rendered in connection with a compromise of the levy made under the provisions of section 608 of the Revenue Act of 1918. The balance of the attorney's fees was paid for services in connection with criminal charges brought against petitioner and one of his truck…
1Opinion of the Court
*100OPINION.
Smith:
The issues before us are (1) the deductibility of $11,200 paid out during 1922 in compromise of a $25,000 tax, and (2) the deductibility of certain attorney’s fees of which $10,000 was paid during 1922 and $3,000 during 1923.
Section 608 of the Revenue Act of 1918 reads as follows:
That there shall be levied and collected on all beer, lager beer, ale, porter, and other similar fermented liquor, containing one-half of one per centum, or more, of alcohol, brewed or manufactured and hereafter sold, or removed for consumption or sale, within the United States, by whatever name such…
2Cases cited10 opinions
- United States v. One Ford Coupe AutomobileSupreme Court of the United States · 1926
- Lipke v. LedererSupreme Court of the United States · 1922
- United States v. YuginovichSupreme Court of the United States · 1921
- United States v. StafoffSupreme Court of the United States · 1923
- Helwig v. United StatesSupreme Court of the United States · 1903
5 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- M.H. Bell and Bettie Lou Bell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- United States v. JaffrayCourt of Appeals for the Eighth Circuit · 1938
- Hales-Mullaly, Inc. v. CommissionerUnited States Board of Tax Appeals · 1942
- Levinstein v. CommissionerUnited States Board of Tax Appeals · 1930
- Spaeth v. CommissionerUnited States Tax Court · 1962