Mauerman v. Commissioner
United States Tax Court
Petitioner made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1984 and 1986. Petitioner deducted the payments to Pre-Paid on his 1984 and 1986 tax returns. Petitioner should have amortized the payments over 5 years.
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Petitioner made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1984 and 1986. Petitioner deducted the payments to Pre-Paid on his 1984 and 1986 tax returns. Petitioner should have amortized the payments over 5 years. Petitioner and respondent have settled the deficiencies; the dispute is whether petitioner is liable for additions to tax for 1984 under sec. 6661(a), I.R.C. 1954, and for 1986 under sec. 6661(a), I.R.C. 1986. 1. Held: Petitioner did not have substantial…
1Opinion of the Court
GEORGE S. MAUERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mauerman v. Commissioner
Docket No. 3007-90
United States Tax Court
T.C. Memo 1993-23; 1993 Tax Ct. Memo LEXIS 21; 65 T.C.M. (CCH) 1772;
January 19, 1993, Filed
Decision will be entered for respondent as to 1984 and 1986, and for petitioner as to 1985.
Petitioner made payments to Pre-Paid Legal Services, Inc. (Pre-Paid), to buy the right to receive 5 years' premium income on legal service contracts issued by Pre-Paid to clients in 1984 and 1986. Petitioner deducted the payments to Pre-Paid on his 1984 and 1986 tax…
2Cases cited26 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Burnet v. HarmelSupreme Court of the United States · 1932
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Helvering v. StuartSupreme Court of the United States · 1942
- Pallottini v. CommissionerUnited States Tax Court · 1988
21 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- William D. Little v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
- Estate of Owen v. CommissionerUnited States Tax Court · 1995
- Estate of Owen v. CommissionerUnited States Tax Court · 1995
- Martin v. CommissionerUnited States Tax Court · 1995
- Mauerman v. CommissionerUnited States Tax Court · 1995
2 more not listed; retrieve them via the Exa API.