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SHARPLES v. UNITED STATES

No. 63-73.

533 F.2d 550 (1976)

Philip T. and Edith W. SHARPLES v. The UNITED STATES.

United States Court of Claims.

April 14, 1976.

Attorney(s) appearing for the Case

William L. Goldman, Washington, D.C., for plaintiff; Thomas E. Jenks, Washington, D.C., atty. of record for plaintiff; John M. Skilling, Jr., Washington, D.C., and Herbert L. Awe, Washington, D.C., of counsel.

Allan C. Lewis, Washington, D.C., with whom was Asst. Atty. Gen., Scott P. Crampton, Washington, D.C., for defendant; Theodore D. Peyser, Jr., and Donald H. Olson, Washington, D.C., of counsel.

Before NICHOLS, KASHIWA and KUNZIG, Judges.

OPINION

KUNZIG, Judge.

In this income tax refund suit plaintiff seeks a 1966 deduction for legal expenses incurred while resisting a Venezuelan tax deficiency. The potential Venezuelan tax liability devolved on plaintiff as the recipient of assets from a liquidated corporation that would have incurred the tax. The issue comes before the court for resolution based upon the parties' stipulation of facts pursuant to...

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