Income Tax Keyed to Lind
Bowers v. Lumpkin
Plaintiff, Mrs. Lumpkin, filed suit to recover overpaid federal income taxes. Plaintiff had a life interest in one-half of the stock of corporation which owned sale and distribution rights to coca-cola syrup. The life interest was under a trust created by her former husband’s will. Plaintiff purchased remaining stock of the corporation from other trustees to whom it was bequeathed. The Attorney General sued to invalidate the sale because the stock was bequeathed to those trustees in order to establish an orphanage. Plaintiff spent litigation costs defending the sale and won. She incurred $26,798.22 in legal expenses. She deducted those expenses from her gross income. The Commissioner of the Internal Revenue Service did not allow the deductions and assessed taxes and interests. Plaintiff paid under protest and filed suit and won in District Court.
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