Cardinal Corp. v. Commissioner
United States Tax Court
1. Held, an amount received by petitioner in 1958 was not includable in gross income. Such amount was received in exchange for stock of petitioner under sec. 1032, I.R.C. 1954. 2. Held, further, legal fees paid by petitioner in 1958 were for services rendered to petitioner.
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1. Held, an amount received by petitioner in 1958 was not includable in gross income. Such amount was received in exchange for stock of petitioner under sec. 1032, I.R.C. 1954. 2. Held, further, legal fees paid by petitioner in 1958 were for services rendered to petitioner. Petitioner is entitled to deduct the legal fees as an ordinary and necessary expense under sec. 162(a), I.R.C. 1954. 3. Held, further, actuarial fees paid by petitioner in 1958 were for services rendered to petitioner. Petitioner is entitled to deduct the actuarial fees as an ordinary and necessary expense under sec.…
1Opinion of the Court
Cardinal Corporation, Louisville, Kentucky (Formerly: Cardinal Life Insurance Co.), Petitioner v. Commissioner of Internal Revenue, Respondent
Cardinal Corp. v. Commissioner
Docket No. 4778-64
United States Tax Court
52 T.C. 119; 1969 U.S. Tax Ct. LEXIS 151;
April 21, 1969, Filed
Decision will be entered under Rule 50.
1. Held, an amount received by petitioner in 1958 was not includable in gross income. Such amount was received in exchange for stock of petitioner under sec. 1032, I.R.C. 1954.
2. Held, further, legal fees paid by petitioner in 1958 were for services rendered to petitioner. Petitioner…
2Cases cited17 opinions
- Pepper v. LittonSupreme Court of the United States · 1939
- Huddleston v. DwyerSupreme Court of the United States · 1944
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Zahn v. Transamerica CorporationCourt of Appeals for the Third Circuit · 1947
- Pike v. CommissionerUnited States Tax Court · 1965
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