Thomas v. Commissioner
United States Tax Court
Held, legal expenses incurred by petitioners in settling disputed Federal income tax liabilities for prior years are deductible under section 62, I.R.C. 1954, in computing adjusted gross income.
1Opinion of the Court
OPINION
Bruce, Judge:
Respondent determined a deficiency in the income tax of petitioners for the taxable year 1959 in the amount of $150. The sole issue is whether a legal fee paid by petitioners in connection with the settlement of their disputed Federal income tax liabilities for prior years is deductible in computing adjusted gross income under section 62(1) of the Internal Revenue Code of 19541 for the year 1959.
The facts are fully stipulated and are found accordingly.
Petitioners are husband and wife who reside in Big Spring, Tex. They filed their joint Federal income tax return for the…
2Cases cited11 opinions
- Commissioner v. BilderSupreme Court of the United States · 1962
- Commissioner of Internal Revenue v. Frank Polk and Marie PolkCourt of Appeals for the Tenth Circuit · 1960
- Polk v. CommissionerUnited States Tax Court · 1958
- Commissioner of Internal Revenue v. James J. Standing and Marie S. StandingCourt of Appeals for the Fourth Circuit · 1958
- Standing v. CommissionerUnited States Tax Court · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Tanner v. CommissionerUnited States Tax Court · 1965
- Tanner v. CommissionerUnited States Tax Court · 1965
- Thomas v. CommissionerUnited States Tax Court · 1964