OWENS v. COMMISSIONER

Docket No. 58812.

17 T.C.M. 519 (1958)

T.C. Memo. 1958-103

Shelby Owens and Dorothy H. Owens, Husband and Wife v. Commissioner.

United States Tax Court.

Filed May 29, 1958.


Attorney(s) appearing for the Case

Robert J. Hobby, Esq., and Wentworth P. Durant, Esq., 1520 Republic Bank Building, Dallas, Tex., for the petitioners. Carswell H. Cobb, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

TRAIN, Judge:

Respondent determined a deficiency in petitioners' income tax for the year 1953 in the amount of $4,684.88. Petitioners dispute only the disallowance of the deduction of $7,500 in attorney's fees. The sole issue for determination is whether the sum of $7,500, which was paid to an attorney in 1953, is an expense incurred for the production of income or for the management, conservation, or maintenance of...

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