Estate of Rockefeller v. Commissioner

762 F.2d 264 (1985), cert. denied 474 U.S. 1037 (1986)

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Estate of Rockefeller v. Commissioner

United States Court of Appeals for the Second Circuit
762 F.2d 264 (1985), cert. denied 474 U.S. 1037 (1986)

Facts

Nelson A. Rockefeller (plaintiff) was the governor of New York between 1959 and 1973. Rockefeller had held various government positions before becoming governor, but none since 1955. Rockefeller eventually retired to fully commit as the chairman of the Commission on Critical Choices for Americans and the chairman of the National Commission on Water Quality. After President Nixon’s sudden resignation in 1974, Rockefeller had the opportunity to become the vice president of the United States upon confirmation by the Senate and the House of Representatives. On his 1974 federal tax return, Rockefeller deducted costs related to his confirmation as business expenses. The commissioner of internal revenue (commissioner) (defendant) disallowed the deductions. Rockefeller petitioned for a redetermination in the United States Tax Court. The tax court ruled for the commissioner, and Rockefeller appealed.

Rule of Law

Issue

Holding and Reasoning (Friendly, J.)

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