Legal Opinion

Drayton Heard and Elizabeth A. Heard v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided August 12, 1959No. 12882PublishedCited by 23 opinions

1Opinion of the Court

McLAUGHLIN, Circuit Judge.

Petitioners ask for review of a decision of the Tax Court, 30 T.C. 1093 (1958), which held that the premiums paid by taxpayer for old line health and accident policies are a medical deduction under § 23 (x) of the 1939 Internal Revenue Code as amended 26 U.S.C. 1952 ed., only to the extent that they are applied to medical or hospitalization coverage. Petitioners also except to the determination that mailing before midnight of the final day of the allowed period is not a “filing” under § 294(d)(1)(A), 26 U.S. C.; that double penalties for underestimation and untimely…

2Cases cited12 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. United States v. LombardoSupreme Court of the United States · 1916
  3. Fred N. Acker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
  4. J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  5. Josef C. Patchen and Aleyne E. Patchen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958

7 more not listed; retrieve them via the Exa API.

3Cited by23 opinions

  1. Philadelphia Marine Trade Ass'n-International Longshoremen's Ass'n Pension Fund v. CommissionerCourt of Appeals for the Third Circuit · 2008
  2. Hotel Equities Corp. v. CommissionerUnited States Tax Court · 1975
  3. Edwards v. CommissionerUnited States Tax Court · 1962
  4. O'Donnabhain v. CommissionerUnited States Tax Court · 2010
  5. Kilgore v. CommissionerUnited States Tax Court · 1962

18 more not listed; retrieve them via the Exa API.

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