Legal Opinion
Of Course, Inc., (Formerly: The Isaac Hamburger & Sons Company), a Maryland Corporation in Dissolution v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided July 2, 1974No. 73-1495PublishedCited by 25 opinions
1Opinion of the Court
DONALD RUSSELL, Circuit Judge:
This appeal poses for determination the deductibility as a business expense, qualifying under Section 162(a), 26 U.S.C. (Internal Revenue Code of 1954) of attorneys’ fees incurred in connection with the sale of capital assets in a Section 337(a), Internal Revenue Code of 1954, corporate liquidation. The corporate taxpayer involved adopted its plan of liquidation on January 18, 1968 and made the sale of its assets on February 5, 1968. It realized a capital gain in excess of $10,000 on this sale. It, however, made no report of such gain as income on its tax return…
2Cases cited26 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- National Labor Relations Board v. Insurance Agents' International UnionSupreme Court of the United States · 1960
- Dixon v. United StatesSupreme Court of the United States · 1965
- Woodward v. CommissionerSupreme Court of the United States · 1970
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
21 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Lawrence Keasler and Keasler Body Company, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1985
- H. David Boyter and Angela M. Boyter v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1981
- Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Atlas Tool Co., Inc., Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc., Stephan Schaffan and Mildred Schaffan, Atlas Tool Co., Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7633-74). Atlas Tool Co., Inc., Successor to Fletcher Plastics, Inc. v. Commissioner of Internal Revenue, (Tax Court Docket No. 7634-74). Stephan Schaffan and Mildred Schaffan v. Commissioner of Internal Revenue, (Tax Court Docket No. 7635-74). Appeal of Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1980
- Allstate Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1977
- Stewart Trust v. CommissionerUnited States Tax Court · 1975
20 more not listed; retrieve them via the Exa API.