Legal Opinion
Keystone Metal Company v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided February 26, 1959No. 12672PublishedCited by 3 opinions
1Opinion of the Court
HASTIE, Circuit Judge.
This is a petition for review of a decision of the Tax Court upholding the Commissioner’s finding of a deficiency in petitioner’s 1953 income tax return. The Tax Court held that in the circumstances of this case statutory penalties paid to the City of Pittsburgh and the School District of Pittsburgh for late payment of certain mercantile taxes are not deductible from gross incomes as “ordinary and necessary” business expenses within the meaning of Section 23(a) of the Internal Revenue Code of 1939. 26 U.S.C., 1952 ed., § 23(a). The deductions were disapproved on the…
2Cases cited20 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Wilson v. Philadelphia School DistrictSupreme Court of Pennsylvania · 1937
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Oklahoma Operating Co. v. LoveSupreme Court of the United States · 1920
- Wadley Southern Railway Co. v. GeorgiaSupreme Court of the United States · 1915
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3Cited by3 opinions
- Dukehart-Hughes Tractor & Equipment Co., Inc., a Corporation v. The United StatesUnited States Court of Claims · 1965
- Dukehart-Hughes Tractor & Equipment Co., Inc., a Corporation v. The United StatesUnited States Court of Claims · 1965
- Keystone Metal Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959