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COLLINS v. COMMISSIONER

Docket No. 3116-67.

54 T.C. 1656 (1970)

JAMES A. COLLINS AND DOROTHY O. COLLINS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 27, 1970.

Attorney(s) appearing for the Case

Justin L. Goldner, for the petitioners.

Myron A. Weiss and Robert H. Feldman, for the respondent.

MULRONEY, Judge:

Respondent determined a deficiency in petitioners' 1962 income tax in the amount of $36,276.50. Certain adjustments have not been contested by the parties. The issues to be decided are (1) whether petitioners are entitled to deduct $44,299.70 as interest expense under section 163, I.R.C. 1954,1 and (2) whether petitioners are entitled to deduct all or any part over $300 of the sum of $4,461 paid by them as legal...

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