Burnett v. Commissioner
United States Tax Court
Held, certain advances made by petitioner-lawyer on behalf of his clients are not ordinary and necessary business expenses deductible under section 162, I.R.C. 1954.
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the taxable year 1961 as follows:
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The sole issue is whether certain expenditures made by petitioner to or on behalf of his clients in 1961 which were to be repaid upon the successful resolution of their legal claims are deductible in the year made as ordinary and necessary business expenses under section 162 of the Internal Revenue Code of 1954.
FINDINGS OP PACT
The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Petitioners are husband and wife who…
2Cases cited5 opinions
- Reginald G. Hearn and Mary L. Hearn, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Hearn v. CommissionerUnited States Tax Court · 1961
- Cochrane v. CommissionerUnited States Board of Tax Appeals · 1931
- Drachman v. CommissionerUnited States Tax Court · 1954
- Albright v. CommissionerUnited States Board of Tax Appeals · 1929
3Cited by15 opinions
- Canelo v. CommissionerUnited States Tax Court · 1969
- Warren Burnett and Emma Burnett v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Humphrey, Farrington & McClain, P.C. v. Comm'rUnited States Tax Court · 2013
- Herrick v. CommissionerUnited States Tax Court · 1975
- Boccardo v. United StatesUnited States Court of Claims · 1987
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