EISLER v. COMMISSIONER

Docket No. 7463-70.

59 T.C. 634 (1973)

GEORGE EISLER AND RIANE EISLER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 5, 1973.


Attorney(s) appearing for the Case

Bruce I. Hochman and Harvey D. Tack, for the petitioners.

H. Lloyd Nearing, for the respondent.


The Commissioner determined a $50,738.75 deficiency in petitioners' income tax for the calendar year 1966. The only issue for decision is whether petitioner George Eisler's payment of $235,000 in settlement of a lawsuit, and legal fees of $55,094.85 incurred by Eisler in connection with that lawsuit, represented ordinary expenses or losses or capital outlays.

FINDINGS OF FACT

The parties have filed a stipulation of facts which, together with accompanying...

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