Legal Opinion

Mauerman v. Commissioner

United States Tax Court

Decided January 19, 1993No. Docket No. 3007-90UnpublishedCited by 7 opinions

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

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Burnet v. HarmelSupreme Court of the United States · 1932
  3. Morgan v. CommissionerSupreme Court of the United States · 1940
  4. Helvering v. StuartSupreme Court of the United States · 1942
  5. Pallottini v. CommissionerUnited States Tax Court · 1988

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

3Cited by7 opinions

  1. William D. Little v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
  2. Estate of Owen v. CommissionerUnited States Tax Court · 1995
  3. Estate of Owen v. CommissionerUnited States Tax Court · 1995
  4. Martin v. CommissionerUnited States Tax Court · 1995
  5. Mauerman v. CommissionerUnited States Tax Court · 1995

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

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