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BILAR TOOL & DIE CORPORATION v. COMMISSIONER

Docket No. 7411-72.

62 T.C. 213 (1974)

BILAR TOOL & DIE CORPORATION, FORMERLY FORWAY TOOL & DIE CO., INC., A MICHIGAN CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 15, 1974.

Attorney(s) appearing for the Case

Richard U. Mosher, for the petitioner.

Peter M. Ritteman, for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency of $5,520 in petitioner's Federal income tax for the fiscal year ended September 30, 1967. The only issue before the Court is whether petitioner is entitled to a deduction from its gross income as ordinary and necessary business expense under section 162(a) legal expenses incurred by it in a division of its business between its two 50-percent shareholders in the tax year at bar.

FINDINGS OF FACT

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