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SOUTHLAND ROYALTY CO. v. U. S.

No. 12-75.

582 F.2d 604 (1978)

SOUTHLAND ROYALTY COMPANY v. The UNITED STATES.

United States Court of Claims.

July 14, 1978.

Attorney(s) appearing for the Case

R. Gordon Appleman, Fort Worth, Tex., attorney of record for plaintiff. Bird & Appleman, Fort Worth, Tex., of counsel.

Donald H. Olson, Washington, D.C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D.C., for defendant. Theodore D. Peyser, Jr., Washington, D.C., of counsel.

Before COWEN, Senior Judge, and DAVIS and KUNZIG, Judges.

OPINION

DAVIS, Judge.

This is a corporate income tax dispute whether certain business expenditures should be deducted as ordinary and necessary expenses or should be capitalized. Taxpayer Southland Royalty Company ("Southland") is engaged in the oil and gas business. It keeps its books and reports its income and expenses for federal income tax purposes on the calendar year and accrual bases. The controversy resolves around the deductibility of legal expenses...

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