Legal Opinion

Thomas v. Commissioner

United States Tax Court

Decided February 12, 1964No. Docket No. 93556Published

Held, legal expenses incurred by petitioners in settling disputed Federal income tax liabilities for prior years are deductible under section 62, I.R.C. 1954, in computing adjusted gross income.

1Opinion of the Court

Clyde E. Thomas, Sr., and Reba E. Thomas, Petitioners, v. Commissioner of Internal Revenue, Respondent

Thomas v. Commissioner

Docket No. 93556

United States Tax Court

41 T.C. 614; 1964 U.S. Tax Ct. LEXIS 151;

February 12, 1964, Filed

Decision will be entered for the petitioners.

Held, legal expenses incurred by petitioners in settling disputed Federal income tax liabilities for prior years are deductible under section 62, I.R.C. 1954, in computing adjusted gross income.

Julius C. Calhoun, for the petitioners.

Bruce Hallmark , for the respondent.

Bruce, Judge.

BRUCE

OPINION

Respondent determined a…

2Cases cited12 opinions

  1. Commissioner v. BilderSupreme Court of the United States · 1962
  2. Commissioner of Internal Revenue v. Frank Polk and Marie PolkCourt of Appeals for the Tenth Circuit · 1960
  3. Polk v. CommissionerUnited States Tax Court · 1958
  4. Commissioner of Internal Revenue v. James J. Standing and Marie S. StandingCourt of Appeals for the Fourth Circuit · 1958
  5. Standing v. CommissionerUnited States Tax Court · 1957

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