Legal Opinion

Garrett v. Crenshaw

Court of Appeals for the Fourth Circuit

Decided April 23, 1952No. 6396PublishedCited by 39 opinions

1Opinion of the Court

PARKER, Chief Judge.

This is an appeal from a judgment for defendant in an action instituted against a Collector of Internal Revenue to recover deficiencies in income taxes assessed against and paid by plaintiff. The question involved is whether expenditures in a suit to establish that certain income producing property was held in trust for plaintiff were deductible as ordinary and necessary expenses under either subsection (1) (A) or subsection (2) of Section (23) (a) of the Internal Revenue Code, 26 U.S.C. § 23(a). We think that the question was properly answered in the negative by the…

2Cases cited4 opinions

  1. Kornhauser v. United StatesSupreme Court of the United States · 1928
  2. Hochschild v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1947
  3. Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
  4. Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946

3Cited by39 opinions

  1. Harrison E. Spangler and Myrtle B. Spangler v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
  2. Joseph Lewis v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
  3. Daniel S. W. Kelly v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  4. Industrial Aggregate Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
  5. Kelly v. CommissionerUnited States Tax Court · 1955

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