WALLACE v. COMMISSIONER

Docket No. 186-69.

56 T.C. 624 (1971)

WILLIAM F. WALLACE, SR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 23, 1971.


Attorney(s) appearing for the Case

Robert Burke, for the petitioner.

Harold Friedman, for the respondent.


SIMPSON, Judge:

The respondent determined deficiencies in the income tax of the petitioner of $52,192.30 for 1964 and $2,594.25 for 1965. The issue for decision is whether the petitioner is entitled to deduct certain amounts paid to settle the liability of himself and his younger son with respect to lawsuits brought against them by the petitioner's elder son, and amounts paid for related legal services, as ordinary and necessary business expenses, or as ordinary...

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