Bowers v. Lumpkin
United States Court of Appeals for the Fourth Circuit
140 F.2d 927 (1944)
- Written by Sara Rhee, JD
Facts
Lumpkin (plaintiff) inherited half the stock of a certain corporation and purchased the remainder. The Attorney General of South Carolina challenged the validity of her purchase. The taxpayer defended her title to the property in court and prevailed. She incurred litigation expenses of $250 in 1936 and $26,798.22 in 1937. Lumpkin deducted these amounts as ordinary and necessary expenses. The Commissioner of Internal Revenue disallowed the deductions and assessed additional taxes. Lumpkin paid the taxes but then brought suit in federal district court against Bowers (defendant), the tax collector for South Carolina, to recover the allegedly overpaid taxes. The district court ruled in Lumpkin’s favor, and Bowers appealed.
Rule of Law
Issue
Holding and Reasoning (Soper, J.)
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