U.S. Court of Appeals for the Sixth Circuit, 1953

Brand v. Commissioner of Internal Revenue

U.S. Court of Appeals for the Sixth Circuit · Decided December 14, 1953 · Simons, Allen, Miller

209 F.2d 255; 45 A.F.T.R. (P-H) 116; 1953 U.S. App. LEXIS 4440 (Federal Reporter, Second Series)

Counsel

Petitioners not represented., Lester Brand, in pro. per., H. Brian Holland, Ellis N. Slack, Helen Goodner, Dudley J. Godfrey, Washington, D. C., Kenneth W. Gemmill, Philadelphia, Pa., and Rolling H. Transue, Washington, D. C., for respondent.

Cases that cite this one

2 later published cases cite this decision.

The Crosley Corporation v. United States (6th Cir. 1956)
Commissioner of Internal Revenue v. Adam, Meldrum & Anderson Co., Inc (2d Cir. 1954)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

PER CURIAM.

This case having been considered by the Court on the record, briefs and oral argument on behalf of the respective parties;

And the Court being of the opinion that the ruling of the Tax Court that the $2,700 paid by petitioners for the purpose of protecting and perfecting the title to real estate in which the petitioners had an interest was a capital expenditure and not a deductible expense for income tax purposes under Section 23 (a) (1) or (2) or Section 23(e), Internal Revenue Code, 26 U.S.C.A., was not erroneous; Safety Tube Corp. v. Commissioner, 6 Cir., 168 F.2d 787, 789; Porter Royalty Pool v. Commissioner, 6 Cir., 165 F.2d 933, 936; Jones’ Estate v. Commissioner, 5 Cir., 127 F.2d 231; A. Giur-lani & Bro. v. Commissioner, 9 Cir., 119 F.2d 852, 857.

It is ordered that the judgment of the Tax Court is affirmed.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.