Legal Opinion

Bird v. Commissioner

United States Tax Court

Decided April 5, 1967No. Docket No. 3169-65Unpublished

Held, petitioners failed to carry their burden of proving that they are entitled to deduct (1) amounts purportedly withheld by insurance company, from commissions due petitioners, as reimbursement for shortages in petitioner's accounts with insurance company, (2) certain amounts of interest claimed on returns, and (3) business rent determined by respondent to have been reimbursed by insurance company.

1Opinion of the Court

Mark A. Bird and Phyllis K. Bird v. Commissioner.

Bird v. Commissioner

Docket No. 3169-65.

United States Tax Court

T.C. Memo 1967-69; 1967 Tax Ct. Memo LEXIS 194; 26 T.C.M. (CCH) 363; T.C.M. (RIA) 67069;

April 5, 1967

Held, petitioners failed to carry their burden of proving that they are entitled to deduct (1) amounts purportedly withheld by insurance company, from commissions due petitioners, as reimbursement for shortages in petitioner's accounts with insurance company, (2) certain amounts of interest claimed on returns, and (3) business rent determined by respondent to have been reimbursed by…

2Cases cited13 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Halle v. CommissionerUnited States Tax Court · 1946
  3. Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
  4. Reinecke v. SpaldingSupreme Court of the United States · 1930
  5. Hague Estate v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943

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