Legal Opinion
Simon v. Commissioner
Court of Appeals for the Third Circuit
Decided October 7, 1987No. Nos. 86-5911 to 86-5914PublishedCited by 26 opinions
1Opinion of the Court
OPINION OF THE COURT
GIBBONS, Chief Judge.
These four consolidated appeals are from a final order of the United State Tax Court determining that there was a deficiency in the taxpayers’ federal income tax for the taxable year 1976.1 At issue are claimed deductions for expenses paid or incurred in that year in carrying out a trade or business, or for the production or collection of income. 26 U.S.C. §§ 162(a)(3), 212(1) (1954). The expenses sought to be deducted are $6,000,000 in advance royalties, and $75,000 in management and legal fees, accrued by a limited partnership, Tennessee Coal…
2Cases cited23 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Golanty v. CommissionerUnited States Tax Court · 1979
- Malat v. RiddellSupreme Court of the United States · 1966
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
18 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Portland Golf Club v. CommissionerSupreme Court of the United States · 1990
- Pleasant Summit Land Corp. v. CommissionerCourt of Appeals for the Third Circuit · 1988
- Michael v. Frierdich and Connie J. Frierdich v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
21 more not listed; retrieve them via the Exa API.