Income Tax Keyed to Lind
Commissioner v. Tellier
Facts
Respondent, Walter Tellier, was in the business of underwriting the public sale of stock offerings and purchasing securities for resale to customers. In 1956 he was tried on a 36 count indictment for violating the fraud section of the Securities Act of 1933 and with mail fraud. He was found guilty and sentenced to four and a half years in prison and fined $18,000. He spent $22,964 on his criminal defense legal expenses, and he claimed a deduction for that amount on his tax return. The Commissioner did not allow the deduction and the Tax Court affirmed, and the Court of Appeals reversed.
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