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COKE v. COMMISSIONER

Docket No. 25822.

17 T.C. 403 (1951)

AGNES PYNE COKE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 24, 1951.

Attorney(s) appearing for the Case

John N. Jackson, Esq., for the petitioner.

J. Marvin Kelley, Esq., for the respondent.

Respondent determined a deficiency for the calendar year 1945 in the amount of $20,890.13. Petitioner claims an overpayment. The sole issue is whether petitioner is entitled to deduct, in whole or in part, certain attorneys' fees and costs as "non-trade or non-business expenses" under section 23 (a) (2), Internal Revenue Code. The facts have been stipulated.

FINDINGS OF FACT.

Petitioner is an individual with her...

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