Higgins v. Commissioner
United States Tax Court
The cost of tax advice and of the preparation of income tax returns may or may not be deducted as a nontrade or nonbusiness expense under section 23 (a) (2) of the Internal Revenue Code, depending upon whether such cost is proximately related to the production or collection of income or the management, conservation or maintenance of property held for the production of income.
1Opinion of the Court
OPINION.
Arundell, Judge:
The Commissioner determined a deficiency in income tax for the year 1939 in the amount of $881.32. Petitioner filed his return in the district of Massachusetts.
The case is submitted upon a very short stipulation of facts, from which it appeárs that petitioner in 1939 paid the law firm of Hale & Dorr, Boston, Massachusetts, legal fees in the amount of $3,794.13 for services and advice from February 8, 1938, to June 2, 1939. Of this amount $2,544.13 was paid in connection with problems relating to the management and investment of the property of petititoner and was…
2Cases cited2 opinions
- Coffey v. CommissionerUnited States Tax Court · 1943
- Willmott v. CommissionerUnited States Tax Court · 1943
3Cited by14 opinions
- Loew v. CommissionerUnited States Tax Court · 1946
- Williams v. CommissionerUnited States Tax Court · 1944
- Hogan v. CommissionerUnited States Tax Court · 1944
- Davis v. CommissionerUnited States Tax Court · 1944
- Armour v. CommissionerUnited States Tax Court · 1946
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