Legal Opinion
Commissioner of Internal Revenue v. Hymie Schwartz and Jeannette L. Schwartz
Court of Appeals for the Fifth Circuit
Decided March 14, 1956No. 15422PublishedCited by 17 opinions
1Opinion of the Court
CAMERON, Circuit Judge.
This Petition for Review presents for decision the question whether attorneys’ fees paid by the taxpayer1 in 1950 in connection with his income tax liabilities for prior years were deductible as ordi*95nary and necessary expense under Section 23(a) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 23(a), as held by the Tax Court; or whether they were really paid in an attempt to forestall an indictment for fraud and are, therefore, non-deductible as personal expenses under Section 24 of the Code, 26 U.S.C.A. § 24, and on grounds of public policy. For the reasons…
2Cases cited9 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Lykes v. United StatesSupreme Court of the United States · 1952
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Commissioner of Int. Rev. v. Longhorn Portland Cem. Co.Court of Appeals for the Fifth Circuit · 1945
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Commissioner v. TellierSupreme Court of the United States · 1966
- California and Hawaiian Sugar Refining Corporation, Limited v. The United StatesUnited States Court of Claims · 1962
- Segall v. CommissionerUnited States Tax Court · 1958
- Commissioner of Internal Revenue v. Michael Shapiro and Rae ShapiroCourt of Appeals for the Seventh Circuit · 1960
- S. B. Brinson and Leota L. Brinson v. Laurie W. Tomlinson, Director of Internal Revenue for the District of FloridaCourt of Appeals for the Fifth Circuit · 1959
12 more not listed; retrieve them via the Exa API.