Snow v. Commissioner
United States Tax Court
For many years prior to 1953, petitioners were partners in a law firm which had derived steady and substantial fees from making abstracts and rendering opinions as to titles to real estate for lenders of money with realty as security. The law partnership had accumulated abstracts or back titles to virtually every subdivision in Bibb County, Macon, Georgia, enabling them to check titles and render opinions thereon very profitably.
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For many years prior to 1953, petitioners were partners in a law firm which had derived steady and substantial fees from making abstracts and rendering opinions as to titles to real estate for lenders of money with realty as security. The law partnership had accumulated abstracts or back titles to virtually every subdivision in Bibb County, Macon, Georgia, enabling them to check titles and render opinions thereon very profitably. Fees from such work, however, declined for several years prior to 1953 because various money lenders, who had supplied a large part of the loan money to purchasers…
1Opinion of the Court
Fisher, Judge:
This consolidated proceeding involves deficiencies determined against petitioners as follows:
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The sole issue presented for our decision herein is whether petitioners are entitled to deduct payments (each in the amount of $1,136.70) during the taxable year 1954, made pursuant to an agreement to guarantee the deficits of a newly organized savings and loan association, as ordinary and necessary business expenses of their law firm under section 162 (a), Code of 1954.
FINDINGS OF FACT.
Most of the facts are stipulated and, as stipulated, are incorporated herein by this…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Owen v. CommissionerUnited States Tax Court · 1954
- Dinardo v. CommissionerUnited States Tax Court · 1954
- L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
7 more not listed; retrieve them via the Exa API.
3Cited by68 opinions
- Mensik v. CommissionerUnited States Tax Court · 1962
- Lohrke v. CommissionerUnited States Tax Court · 1967
- Young & Rubicam, Inc. v. The United StatesUnited States Court of Claims · 1969
- Briarcliff Candy Corporation, (Formerly Loft Candy Corporation) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- Pepper v. CommissionerUnited States Tax Court · 1961
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