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HOFSTEAD v. COMMISSIONER

Docket No. 88877.

21 T.C.M. 1269 (1962)

T.C. Memo. 1962-238

James W. Hofstead and Ellen B. Hofstead v. Commissioner.

United States Tax Court.

Filed October 9, 1962.

Attorney(s) appearing for the Case

K. Harlan Dodson, Jr., Esq., for the Petitioners. Robert L. Ackerson, Esq., for the Respondent.

Memorandum Opinion

ATKINS, Judge:

The respondent determined deficiencies in income tax for the calendar years 1956 and 1957 in the respective amounts of $9,519.13 and $10,570.53.

The sole issue for decision is whether attorney fees paid by petitioner Ellen B. Hofstead in 1956 and 1957 in the respective amounts of $16,540.35 and $19,204.41 are deductible in those years under section 212 (2) of the Internal Revenue Code of 1954

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