Helpful Hints
  • (1) You can search the entire content of Dean’s by phrase or by individual words. Just type your keywords into the search box and then pull down the search icon on the right and choose the option you need: search by word or by phrase or reset the content.
  • (2) Double click on a word in the content of a definition, and if the word is listed as a keyword in Dean’s, it will look that word up.
  • (3) You can use the search function to help jump the scrolling function. Simply type the first 2-3 letters into the search box then hit enter on your keyboard and the scroll will go to those Keywords that begin with those letters and allow you to scroll from there.

 Deductions have been disallowed by the courts, however, where 'the allowance of a deduction would 'frustrate sharply defined national or state policies proscribing particular types of conduct'. . . .' Commissioner v. Tellier, 383 U.S. 687, 694, 16 L. Ed. 2d 185, 86 S. Ct. 1118 (1966) (quoting Commissioner v. Heininger, 320 U.S. 467, 473, 88 L. Ed. 171, 64 S. Ct. 249 (1943)). Thus, 'the 'test of nondeductibilty always is the severity and immediacy of the frustration resulting from allowance of the deduction.'' Id. (quoting Tank Truck Rentals, Inc. v. Commissioner, 356 U.S. 30, 35, 2 L. Ed. 2d 562, 78 S. Ct. 507 (1958)). 

For example, in Tellier, the Tax Court disallowed a deduction for expenses incurred in the unsuccessful defense of a criminal prosecution. The Court reversed, and the Supreme Court affirmed. Emphasizing that 'the 'policies frustrated must be national or state policies evidenced by some governmental declaration of them,'' id. (quoting Lilly v. Commissioner, 343 U.S. 90, 97, 96 L. Ed. 769, 72 S. Ct. 497 (1952)), the Court concluded that 'no public policy is offended when a man faced with serious criminal charges employs a lawyer to ...

Register or login to access full content