DOWD v. COMMISSIONER

Docket No. 4081-74.

68 T.C. 294 (1977)

JOHN DOWD AND HELEN DOWD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 31, 1977.


Attorney(s) appearing for the Case

Richard V. D'Alessandro and E. Michael DiFabio, for the petitioners.

Richard S. Kestenbaum, for the respondent.


GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1969 in the amount of $48,625.97. The issue remaining for decision is whether petitioners may deduct $69,908.67 paid to trade creditors and $7,532.27, the expense of litigation relating thereto, as either ordinary and necessary business expenses or expenses incurred for the production of income.

FINDINGS OF FACT

Some of the facts...

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