Black v. Commissioner
United States Tax Court
Petitioner was employed as a comptroller. Prior to the amendment of sec. 217, I.R.C. 1954, by the 1969 Tax Reform Act, petitioner was transferred from Tiffin, Ohio, to Philadelphia, Pa., by his employer.
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Petitioner was employed as a comptroller. Prior to the amendment of sec. 217, I.R.C. 1954, by the 1969 Tax Reform Act, petitioner was transferred from Tiffin, Ohio, to Philadelphia, Pa., by his employer. Petitioner sold his home in Tiffin and paid a real estate brokerage commission of $ 1,578. He purchased a new home in Pennsylvania and paid a Pennsylvania real estate transfer tax of $ 340. Petitioner also engaged the services of a job-counseling organization for a fee of $ 1,875 to assist him in obtaining a better job. Petitioner obtained new employment; however, the job-counseling…
1Opinion of the Court
Fat, Judge:
Eespondent determined a deficiency in the income tax liability of petitioners for the taxable year 1968 in the amount of $2,853.63. Certain concessions having been made, the issues remaining for decision are: (1) Whether petitioners are entitled to deduct under section 162 or 2121 the commission paid to a real estate broker for the sale of a private residence; (2) whether a Pennsylvania real estate transfer tax is a deductible tax under section 164; and (3) whether petitioners are entitled to a business expense deduction for a fee paid to Frederick Chusid & Co. for services in…
2Cases cited8 opinions
- United States v. GeneresSupreme Court of the United States · 1972
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Cremona v. CommissionerUnited States Tax Court · 1972
- Carey v. CommissionerUnited States Tax Court · 1971
- Giffin v. CommissionerUnited States Board of Tax Appeals · 1930
3 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Estate of Rockefeller v. CommissionerUnited States Tax Court · 1984
- Charles C. Diggs, Jr. And Janet H. Diggs v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1983
- Levy v. United StatesUnited States Court of Claims · 1976
- Cummings v. United StatesDistrict Court, D. Massachusetts · 2011
- Black v. CommissionerUnited States Tax Court · 1973
5 more not listed; retrieve them via the Exa API.