CONNELLY v. COMMISSIONER

Docket Nos. 5153, 6006.

6 T.C. 744 (1946)

JAMES A. CONNELLY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 17, 1946.


Attorney(s) appearing for the Case

M. L. Seidman, C. P. A., and S. J. Lasser, C. P. A., for the petitioner.

Homer F. Benson, Esq., for the respondent.


These proceedings, consolidated for hearing, involve income tax deficiencies for 1940 and 1941 in the respective amounts of $1,229.38 and $3,783.52. The questions in issue are (1) whether contributions made by the petitioner to the McKean County Fair Association in 1940 and 1941 are legal deductions from gross income under section 23 (o) of the Internal Revenue Code, and (2) whether fees paid in 1941 to attorneys for services rendered in litigation contesting the disallowance...

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