Legal Opinion

MacHris v. Commissioner

United States Tax Court

Decided August 11, 1960No. Docket No. 69922Published

Cost of Sale or Ordinary and Necessary Nonbusiness Expense -- Secs. 212, 1201, 1202, 1222, 1954 Code. -- Seller's share of cost of an annual estimate of oil reserves to determine selling price of stock was cost of sale of stock and not ordinary and necessary nonbusiness expense of seller.

1Opinion of the Court

Estate of Bessie E. Machris, Deceased, Citizens National Trust & Savings Bank of Los Angeles, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

MacHris v. Commissioner

Docket No. 69922

United States Tax Court

34 T.C. 827; 1960 U.S. Tax Ct. LEXIS 97;

August 11, 1960, Filed

Decision will be entered for the respondent.

Cost of Sale or Ordinary and Necessary Nonbusiness Expense -- Secs. 212, 1201, 1202, 1222, 1954 Code. -- Seller's share of cost of an annual estimate of oil reserves to determine selling price of stock was cost of sale of stock and not ordinary and necessary…

2Cases cited7 opinions

  1. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  2. Heller v. CommissionerUnited States Tax Court · 1943
  3. Heller v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1945
  4. Naylor v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  5. Commissioner of Internal Revenue v. Arrowsmith Commissioner of Internal Revenue v. VivianCourt of Appeals for the Second Circuit · 1952

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