WILLIAMS v. COMMISSIONER

Attorney(s) appearing for the Case

Robert R. Williams, Jr., Esq., 107 Evelyn Place, Asheville, N. C., for the petitioners. Hubert E. Kelly, Esq., for the respondent.

The respondent determined deficiencies in the Federal income tax of petitioners for the taxable years 1948 and 1949 in the amounts of $1,130.14 and $1,454.28, respectively.

The issues presented are: (1) whether the assessment of a deficiency is barred by the statute of limitations for the year 1948; (2) to what extent, if any, in 1948 and 1949, expenses (including those for gasoline, oil, repair and maintenance, depreciation and insurance) sustained in the operation of an automobile and, in 1949, other traveling expenses while away from home were incurred in carrying on petitioner's professional activity as an attorney; (3) to what extent, if any, expenses for entertaining, gifts, club dues in various organizations, and expenses of attending meetings and conventions of these organizations and a legal clinic, were ordinary and necessary expenses of petitioner's professional activity; (4) the amount of depreciation, if any, allowable on a summer cottage and equipment; and (5) whether net distributable partnership income was properly increased on the basis of certain adjustments for depreciation on washing machines and other equipment used in the operation of a self-service home laundry.

Petitioners do not contest other adjustments made by the respondent by appropriate assignment of error.