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RHOADS v. COMMISSIONER

Docket No. 95089.

22 T.C.M. 1205 (1963)

T.C. Memo. 1963-238

Lynn E. Rhoads and Martha R. Rhoads v. Commissioner.

United States Tax Court.

Filed September 4, 1963.

Attorney(s) appearing for the Case

Sidney Barrows, for the petitioners. Sidney C. Freed, for the respondent.

Memorandum Opinion

FAY, Judge:

The respondent determined a deficiency in petitioners' income tax for 1959 in the amount of $1,398.99. The petitioners claim an overpayment of income tax for 1959 in the amount of $779.50. The primary issue for decision is whether petitioners are entitled to a deduction under either section 165(c)(3) or section 212(2) of the Internal Revenue Code of 1954 for sums paid to settle a legal dispute with persons who sought to obtain...

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