FOSS v. COMMISSIONER OF INTERNAL REVENUE

No. 2930.

75 F.2d 326 (1935)

FOSS et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, First Circuit.

January 16, 1935.


Attorney(s) appearing for the Case

Philip Nichols, of Boston, Mass., for petitioners.

Arnold Raum, Sp. Asst. to Atty. Gen. (Frank J. Wideman, Asst. Atty. Gen., and Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for Commissioner of Internal Revenue.

Before BINGHAM, WILSON, and MORTON, Circuit Judges.


MORTON, Circuit Judge.

This is a petition by the taxpayer to review a decision of the Board of Tax Appeals which sustained the validity of additional income taxes assessed against him for the years 1920 and 1921. Two principal questions are presented — first, whether certain amounts paid by the petitioner during the years in question as attorney's fees were a proper deduction from gross income; second, whether the petitioner in 1920 made a taxable gain on the...

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