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BROWN v. UNITED STATES

Civ. A. No. 28967.

312 F.Supp. 286 (1970)

Prentiss M. BROWN, Jr. and Margaret D. Brown, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, E. D. Michigan, S. D.

May 8, 1970.

Attorney(s) appearing for the Case

Justin C. Weaver, Edward B. Harrison, Leon R. Jones, Fischer, Sprague, Franklin & Ford, Detroit, Mich., for plaintiffs.

Johnnie M. Walters, Asst. Atty. Gen., Tax Division, David A. Wilson, Jr., Chief, Refund Trial Section No. 1, Donald R. Anderson, Daniel P. Mullarkey, Attys., Dept. of Justice, Washington, D. C., James H. Brickley, U. S. Atty., Harold Hood, Asst. U. S. Atty., Detroit, Mich., for defendant.

OPINION AND ORDER DENYING MOTIONS FOR SUMMARY JUDGMENT

LEVIN, District Judge.

This is an action for the recovery of taxes paid. The issue is whether $58,337.86 expended by plaintiffs for legal fees during the years 1959-62 are deductible as expenses incurred for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income. Int.Rev.Code...

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