Legal Opinion

Ander v. Commissioner

United States Tax Court

Decided March 16, 1967No. Docket No. 4724-65PublishedCited by 18 opinions

Held, a reasonable attorney's fee paid in effecting a recovery of sec. 165(c)(3), I.R.C. 1954, theft losses is itself deductible under such section.

1Opinion of the Court

Poreester, Judge:

The respondent determined a deficiency in petitioner’s income tax for -the year 1961 in the amount of $1,240.60. All of the issues save one have been resolved by the parties and such settlements will be reflected in the Rule 60 computation which will be made herein.

The sole issue remaining for our determination is the deductibility of an attorney’s fee of $6,250 paid by petitioner in 1961.

FINDINGS OF FACT

Those facts which are necessary to an understanding of the sole remaining issue in this fully stipulated case are as follows:

Petitioner, hereinafter called Katherine, timely…

2Cases cited10 opinions

  1. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  2. Edwards v. BrombergCourt of Appeals for the Fifth Circuit · 1956
  3. Alison v. United StatesSupreme Court of the United States · 1952
  4. Ticket Office Equipment Co. v. CommissionerUnited States Tax Court · 1953
  5. Earle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1934

5 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Hope v. CommissionerUnited States Tax Court · 1971
  2. Tarsey v. CommissionerUnited States Tax Court · 1971
  3. Schiers v. CommissionerUnited States Tax Court · 1976
  4. Denit v. United StatesDistrict Court, D. Maryland · 1982
  5. Frankel v. CommissionerUnited States Tax Court · 1988

13 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API