KELLY v. COMMISSIONER

Docket No. 37943.

23 T.C. 682 (1955)

DANIEL S. W. KELLY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 24, 1955.


Attorney(s) appearing for the Case

Harvey W. Peters, Esq., for the petitioner.

Edward L. Newberger, Esq., for the respondent.


The respondent determined a deficiency in income tax of the petitioner for the year 1947 in the amount of $1,447.11. The issues for determination are whether (1) legal fees, travel, and out-of-pocket expenses incurred in connection with a lawsuit between petitioner and his sister, and (2) rental of a safety-deposit box amounting to $9.60 are deductible as ordinary and necessary expenses paid during the taxable year "for the production or collection of income, or for the management...

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