BROWN v. COMMISSIONER

Docket No. 8523-71.

32 T.C.M. 1300 (1973)

T.C. Memo. 1973-275

Charles I. Brown and Kathleen M. Brown v. Commissioner.

United States Tax Court.

Filed December 17, 1973.


Attorney(s) appearing for the Case

Stanley L. Drexler, 1700 Broadway, Denver, Colo., and Dale W. Haines, for the petitioners. Arthur B. Bleecher and Norman N. Picket, for the respondent.


Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1968 in the amount of $263.03. The sole issue remaining for our decision is whether payments made by petitioner Charles I. Brown to his employer, pursuant to an alleged violation of section 16(b) of the Securities Exchange Act of 1934, 15 U.S.C.A. sec. 78p(b) are deductible as an ordinary and necessary business expense or as...

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