Legal Opinion

Brown v. United States

District Court, N.D. California

Decided March 30, 1954No. 31683PublishedCited by 8 opinions

1Opinion of the Court

GOODMAN, District Judge.

Plaintiff, the executrix of the estate of Joseph S. Civelli, seeks recovery of $9,193.41 in income taxes allegedly erroneously assessed and collected from the decedent, Civelli. The assessment resulted from the disallowance of a deduction of $12,500 claimed by Civelli in his 1948 income tax return. The deduction represented the sum paid by Civelli in satisfaction of a California judgment in favor of his former wife for 25 monthly payments due her under a settlement agreement incident to their divorce.

Plaintiff asserts that the deduction was properly taken pursuant to…

2Cases cited3 opinions

  1. Hogg v. CommissionerUnited States Tax Court · 1949
  2. Grant v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1953
  3. Laughlin's Estate v. Commissioner of Internal Rev.Court of Appeals for the Ninth Circuit · 1948

3Cited by8 opinions

  1. James B. Taylor and Tevis Bennett Taylor v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
  2. Land v. CommissionerUnited States Tax Court · 1974
  3. Rudolf A. Bernatschke and Cathalene Crane Bernatschke v. The United StatesUnited States Court of Claims · 1966
  4. United States v. SoltermannDistrict Court, N.D. California · 1958
  5. Goninen v. CommissionerUnited States Tax Court · 1983

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