SEFTON v. C. I. R.

No. 17030.

292 F.2d 399 (1961)

J. W. SEFTON, Jr., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

June 28, 1961.


Attorney(s) appearing for the Case

John A. Brant, San Diego, Cal., for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, I. Henry Kutz, Harold M. Seidel and Fred E. Youngman, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before BARNES, HAMLIN and JERTBERG, Circuit Judges.


BARNES, Circuit Judge.

Petitioner sought to redetermine an income tax deficiency assessed against him for the year 1953 in the sum of $14,214.19. This deficiency arose from the disallowance by the Commissioner of two items taxpayer claimed deductible; namely: (1) $39,533.49 allegedly paid by him as interest during 1953;1 and (2) $8,037.06 paid by him as attorneys' fees and costs in certain litigation during 1953.

In 1949 petitioner...

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