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Woodward Vs. Commissioner

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  • US Supreme Court
  • Apr 20, 1970

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42 entries 1 linked 41 unlinked
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  1. Helvering Vs. Winmill US Supreme Court · Nov 07, 1938
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  2. U.S. 572 (1970) U.S. Supreme Court Woodward v. Commissioner
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  3. U.S. 572 (1970) Woodward v. Commissioner
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  4. Page 397 U. S. 573 MR. JUSTICE MARSHALL delivered the opinion of the Court. This case and United States v. Hilton
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  5. interest. The trial court fixed a value, which was slightly reduced on appeal by the Iowa Supreme Court, Woodward v. Quigley
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  6. proceedings between this decision and the decision of the Court of Appeals for the Seventh Circuit in United States v. Hilton
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  7. a)-2(e), and as approved by this Court in Helvering v. Winmill
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  8. U. S. 79 (1938), and Spreckels v. Commissioner
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  9. costs incurred in the acquisition or disposition of such property are capital expenditures. See, e.g., Spangler v. Commissioner
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  10. in incurring them is to defend or perfect title. See, e.g., Rassenfoss v. Commissioner
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  11. Industrial Aggregate Co. v. United
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  12. Ruoff v. Commissioner
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  13. negotiating a purchase of the minority stock would have been capital expenditures. See Atzingen-Whitehouse Dairy Inc. v. Commissioner
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  14. of the stock. Helvering v. Winmill
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  15. with this Court's recent ruling on the characterization of litigation expenses for tax purposes in United States v. Gilmore
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  16. Other federal court decisions on the point are in conflict. Compare Boulder Building Corp. v. United
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  17. D.C.W.D. Okla.1954) (holding appraisal proceeding costs capital expenditures), with Smith Hotel Enterprises, Inc. v. Nelson
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  18. D.C.E.D. Wis.1964) (holding such costs deductible as ordinary and necessary business expense). And see Heller v. Commissioner
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  19. Naylor v. Commissioner
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  20. allows deductions for the ordinary and necessary expenses of nonbusiness profitmaking activities. See United States v. Gilmore
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  21. U. S. 39 , 372 U. S. 44 -45 (1963). Heller v. Commissioner
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  22. See Hochschild v. Commissioner
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  23. Court of Appeals viewed Iowa law differently, and it seems to us that it was correct in so doing. See United States v. Hilton
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  24. Petschek v. United
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  25. the negotiated price and yet considered deductible in the case of the price fixed by law. See Isaac G. Johnson & Co. v. United
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  26. U.S. Supreme Court Woodward v. Commissioner
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  27. and United States v. Hilton
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  28. the Iowa Supreme Court, Woodward v. Quigley
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  29. United States v. Hilton
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  30. and Spreckels v. Commissioner
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  31. Spangler v. Commissioner
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  32. Rassenfoss v. Commissioner
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  33. See Atzingen-Whitehouse Dairy Inc. v. Commissioner
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  34. Compare Boulder Building Corp. v. United
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  35. Smith Hotel Enterprises, Inc. v. Nelson
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  36. Heller v. Commissioner
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  37. Naylor v. Commissioner
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  38. See United States v. Gilmore
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  39. See United States v. Hilton
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  40. Petschek v. United
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  41. See Isaac G. Johnson & Co. v. United
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  42. United States v. Gilmore
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