Legal Opinion
Hermann F. And Madeleine Dupont Ruoff v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided April 6, 1960No. 12907_1PublishedCited by 28 opinions
1Opinion of the Court
KALODNER, Circuit Judge.
Are attorney fees incurred in contesting the Attorney General’s seizure of the taxpayer’s 1 income-producing property under the Trading with the Enemy Act, as amended, 2 deductible from gross income under the provisions of Section 23 of the Internal Revenue Code of 1939, as amended ? 3
The question, of first impression, is presented by this petition for review of the Decision of the Tax Court of the United States which answered it in the negative, five judges dissenting. 4
The facts were stipulated and so found by the Tax Court as follows:
Madeleine duPont Ruoff,…
2Cases cited16 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Stoehr v. WallaceSupreme Court of the United States · 1921
- Cummings v. Deutsche Bank Und DiscontogesellschaftSupreme Court of the United States · 1937
- Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
- Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
11 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970
- Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Anthony J. Accardo and Clarice Accardo v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
- Manufacturers Hanover Trust Company, as Trustee Under Indenture Dated November 15, 1927, Made by Henry H. Rogers, Deceased v. The United StatesUnited States Court of Claims · 1963
23 more not listed; retrieve them via the Exa API.