Fisher v. Commissioner
United States Tax Court
Petitioners made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1983 and 1984. Petitioners deducted the payments paid to Pre-Paid on their 1983 and 1984 tax returns. They should have amortized the payments over 5 years.
Read the full summary
Petitioners made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1983 and 1984. Petitioners deducted the payments paid to Pre-Paid on their 1983 and 1984 tax returns. They should have amortized the payments over 5 years. On their 1983 and 1984 tax returns, petitioners omitted computer business income (1983 only), dividend income, and partnership income (1984 only). They also incorrectly reported interest expense and depreciation expense. Petitioners and respondent have settled…
1Opinion of the Court
ROBERT D. FISHER AND ORPHA L. FISHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fisher v. Commissioner
Docket No. 28630-89
United States Tax Court
T.C. Memo 1992-740; 1992 Tax Ct. Memo LEXIS 777; 64 T.C.M. (CCH) 1670;
December 30, 1992, Filed
Decision will be entered under Rule 155.
Petitioners made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1983 and 1984. Petitioners deducted the payments paid to Pre-Paid on their 1983 and 1984 tax returns. They should have…
2Cases cited28 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Pallottini v. CommissionerUnited States Tax Court · 1988
- United States v. MitchellSupreme Court of the United States · 1971
23 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- George S. Mauerman v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1994