KELLNER v. COMMISSIONER

Docket Nos. 14673-79, 21572-80.

45 T.C.M. 356 (1982)

T.C. Memo. 1982-729

Rose Kellner v. Commissioner.

United States Tax Court.

Filed December 20, 1982.


Attorney(s) appearing for the Case

Robert Greenberg, for the petitioner. Paulette Segal, for the respondent.


[Memorandum Opinion]

DAWSON, Judge:

In these consolidated cases respondent determined deficiencies in petitioner's Federal income taxes for the years 1976 and 1977 in the amounts of $7,773.05 and $13,581.50, respectively.

Concessions have been made by the respondent. At issue is whether the petitioner is entitled to deduct under section 212(1) or (2)1 attorney and accountant fees in (a) her succesful suit against her...

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