Legal Opinion
Charles I. Brown and Kathleen M. Brown v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided January 26, 1976No. 74--1386PublishedCited by 3 opinions
1Opinion of the Court
HOLLOWAY, Circuit Judge.
The Commissioner appeals a Tax Court decision, T.C. Memo 1973-275, holding that the taxpayer appellees 1 were entitled to deduct as an ordinary and necessary business expense a payment made by appellee Charles Brown in settlement of an alleged liability to his employer under § 16(b) of the Securities Exchange Act of 1934, 15 U.S.C.A. § 78p(b).
The Commissioner argues that Brown was only entitled to a long term capital loss deduction, relying on tax benefit principles applied in Arrowsmith v. Commissioner of Internal Revenue, 344 U.S. 6, 73 S.Ct. 71, 97 L.Ed. 6, and…
2Cases cited8 opinions
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- William L. Mitchell and Marian S. Mitchell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- James E. Anderson and Alice Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Anderson v. CommissionerUnited States Tax Court · 1971
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Smith v. CommissionerUnited States Tax Court · 1976
- Mitchell v. CommissionerUnited States Tax Court · 1994
- Smith v. CommissionerUnited States Tax Court · 1976