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MADDEN v. C. I. R.

No. 72-2536.

514 F.2d 1149 (1975)

Blaine M. and Virginia C. MADDEN, Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Ninth Circuit.

April 9, 1975.

Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen. (argued), Washington, D. C., for appellant.

Blaine M. Madden, in pro. per.

Before CHOY and GOODWIN, Circuit Judges, and BURNS, District Judge.

ALFRED T. GOODWIN, Circuit Judge:

The Commissioner of Internal Revenue appeals the judgment of the Tax. Court. determining that legal fees paid by taxpayers are deductible as ordinary and necessary business expenses under section 162(a), Internal Revenue Code of 1954.1 We conclude that the legal fees were capital expenses, and reverse.

Blaine M. and Virginia C. Madden own and operate...

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