TARSEY v. COMMISSIONER

Docket No. 876-70SC.

56 T.C. 553 (1971)

ALEXANDRE R. TARSEY AND TANJA B. R. TARSEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 21, 1971.


Attorney(s) appearing for the Case

Alexandre R. Tarsey and Tanja B. R. Tarsey, pro se.

Norman H. McNeil, for the respondent.


TIETJENS, Judge:

The Commissioner determined a deficiency in petitioners' 1967 Federal income tax in the amount of $123.70. The only issue before us is whether fees paid to file suit to recover for property damages and the amount paid in settlement of a counterclaim for property damages are properly deductible as a casualty loss under section 165(c) (3), I.R.C. 1954.1

FINDINGS OF FACT

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