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WOOD v. COMMISSIONER

Docket No. 85316.

37 T.C. 70 (1961)

CLARENCE WOOD AND MARY LOUISE WOOD, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 23, 1961.

Attorney(s) appearing for the Case

John L. Dorsey, Jr., Esq., for the petitioners.

Arthur N. Mindling, Esq., for the respondent.

OPINION.

MULRONEY, Judge:

The respondent determined a deficiency in the petitioners' income tax for 1955 in the amount of $16,108.71. The sole issue is whether certain attorneys' and accountants' fees totaling $45,000 paid by petitioners in 1958 in contesting and settling their income tax liability for the years 1944, 1945, and 1946 are allowable as business expense deductions in 1958 and in computing their...

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