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IN RE PLACID OIL COMPANY

Civ. A. No. 3-91-0331-G, Bankruptcy No. 386-33419-HCA-11.

148 B.R. 464 (1991)

In re PLACID OIL COMPANY, Debtor. PLACID OIL COMPANY, Appellant, v. INTERNAL REVENUE SERVICE, Appellee.

United States District Court, N.D. Texas, Dallas Division.

November 27, 1991.

Attorney(s) appearing for the Case

William Stephen Swayze, Jr., Kilgore & Kilgore, Khent Hancock Rowton, Dooley & Rucker, Dallas, TX, Michael J. Henke, Vinson & Elkins, Washington, DC, Henry W. Simon, Jr., William Lee White, Seymour Roberts, Jr., Simon Anisman Doby Wilson & Skillern, Ft. Worth, TX, William Douglas Wright, Law Office of William Douglas, Wright, Dallas, TX, for appellant.

Grover Hartt, III, Louise Hytken, U.S. Dept. of Justice, Tax Div., Dallas, TX, for appellee.

MEMORANDUM ORDER

FISH, District Judge.

This case is before the court on appeal from two orders of the bankruptcy court (1) determining that certain professional fees and expenses paid by the debtor, Placid Oil Company ("Placid"), were nondeductible capital expenditures, and (2) disallowing Placid's deduction of a loss claimed in connection with the sale of certain license rights. The bankruptcy court correctly held that the burden of proving that the professional...

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