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COBB v. COMMISSIONER OF INTERNAL REVENUE

No. 10759.

173 F.2d 711 (1949)

COBB v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

April 4, 1949.

Attorney(s) appearing for the Case

W. Dean Hopkins, of Cleveland, Ohio, and John Y. Merrell, of Washington, D. C. (Robert Ash and W. T. Durant, both of Washington, D. C., on the brief), for petitioner.

Howard P. Locke, of Washington, D. C. (Theron Lamar Caudle, Ellis N. Slack and Helen Goodner, all of Washington, D. C., on the brief), for respondent.

Before HICKS, Chief Judge, and SIMONS and MARTIN, Circuit Judges.

MARTIN, Circuit Judge.

The question presented by this petition for review is whether, in the circumstances of the case, the petitioner may deduct from his gross income attorneys' fees paid by him in the taxable year for professional services and advice in relation to a controversy concerning the amount of his liability for gift taxes. The Tax Court of the United States, three judges dissenting, held that such attorneys' fees are not deductible by petitioner under...

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