Legal Opinion

Cummings v. Commissioner

United States Tax Court

Decided April 23, 1973No. Docket No. 2653-71Published

P was a director and shareholder of MGM, and in 1962 he made a payment to MGM of $ 53,870.81 when the SEC indicated that P might be liable to MGM for such amount as an insider's profit within the meaning of sec. 16(b) of the Securities Exchange Act of 1934. Held, under the particular circumstances of this case, the payment is an ordinary and necessary business expense of P.

1Opinion of the Court

Nathan Cummings and Joanne T. Cummings, Petitioners v. Commissioner of Internal Revenue, Respondent

Cummings v. Commissioner

Docket No. 2653-71

United States Tax Court

60 T.C. 91; 1973 U.S. Tax Ct. LEXIS 143; 60 T.C. No. 11;

April 23, 1973, Filed

Decision will be entered for the petitioners.

P was a director and shareholder of MGM, and in 1962 he made a payment to MGM of $ 53,870.81 when the SEC indicated that P might be liable to MGM for such amount as an insider's profit within the meaning of sec. 16(b) of the Securities Exchange Act of 1934. Held, under the particular circumstances of this case,…

2Cases cited12 opinions

  1. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  2. Great Island Holding Corp. v. CommissionerUnited States Tax Court · 1945
  3. Marks v. CommissionerUnited States Tax Court · 1956
  4. William L. Mitchell and Marian S. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
  5. Butler v. CommissionerUnited States Tax Court · 1951

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