Caspers v. Commissioner
United States Tax Court
1. Petitioner, Paul Caspers, has been engaged in the real estate business for more than 40 years. He was so engaged during the years 1953, 1954, and the taxable year 1956. An internal revenue agent examined petitioner's books and records for 1953 and 1954 to determine if his business income had been properly reported. The agent proposed to make nine specific adjustments to petitioners' income.
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1. Petitioner, Paul Caspers, has been engaged in the real estate business for more than 40 years. He was so engaged during the years 1953, 1954, and the taxable year 1956. An internal revenue agent examined petitioner's books and records for 1953 and 1954 to determine if his business income had been properly reported. The agent proposed to make nine specific adjustments to petitioners' income. In January 1956 petitioner was indicted and charged with a violation of section 201, title 18, U.S.C. Petitioner was tried; the jury disagreed; and the indictment, on motion of the Government, was…
1Opinion of the Court
OPINION
Arundell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1956 in the amount of $4,993.07.
The only error originally assigned was that the respondent erred in determining “that the deduction of $9,000.00 for legal expense claimed in yonr Federal income tax return for the taxable year ended December 31, 1956 is not allowable under Section 212, Section 162, or any other section of the Internal Revenue Code of 1954 for the reason that the expenditure was not an ordinary or necessary expense incurred in connection with the determination of any tax liability nor…
2Cases cited11 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Clark v. CommissionerUnited States Tax Court · 1958
6 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Richard H. Dunning and Beulah Marie Dunning v. United StatesCourt of Appeals for the Eighth Circuit · 1965
- Biggs v. CommissionerUnited States Tax Court · 1968
- Caspers v. CommissionerUnited States Tax Court · 1965
- Estate of Trott v. CommissionerUnited States Tax Court · 1969