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ANDERSON-TULLY COMPANY v. COMMISSIONER

Docket No. 18917-81.

48 T.C.M. 415 (1984)

T.C. Memo. 1984-338

Anderson-Tully Company and Subsidiary, Patton-Tully Transportation Company v. Commissioner.

United States Tax Court.

Filed July 3, 1984.

Attorney(s) appearing for the Case

David Wade and Harry J. Skefos, 705 Union Planters Bank Bldg., Memphis, Tenn., for the petitioners. Robert P. Crowther, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Respondent determined deficiencies in petitioners Federal income tax for the fiscal years 1977 and 1978 in the respective amounts of $777.76 and $6,045.54. The only issue for our decision is whether certain legal fees incurred by Anderson-Tully Company were ordinary and necessary business expenses deductible under section 1621 or capital expenditures under section 263.<...

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