SOUTH AMERICAN GOLD & PLATINUM COMPANY v. COMMISSIONER

Docket No. 8681.

8 T.C. 1297 (1947)

SOUTH AMERICAN GOLD & PLATINUM COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 26, 1947.


Attorney(s) appearing for the Case

Edgar J. Goodrich, Esq., Lipman Redman, Esq., and Edward First, Esq., for the petitioner.

Walt Mandry, Esq., for the respondent.


The Commissioner determined a deficiency of $11,504.46 in petitioner's income tax for 1942, in part by disallowing the deduction of a legal fee paid for negotiating and carrying out an agreement whereby litigation and adverse claims against mining rights of its subsidiaries were settled and the subsidiaries acquired additional mines and concessions. Petitioner contends that the fee was an ordinary and necessary expense of conducting its business of directing, guiding, and...

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