PELTON & GUNTHER v. COMMISSIONER

Docket No. 23914-97.

78 T.C.M. 578 (1999)

T.C. Memo. 1999-339

Pelton & Gunther, Professional Corporation v. Commissioner.

United States Tax Court.

Filed October 8, 1999.


Attorney(s) appearing for the Case

Jon L. Brown, for the petitioner. Margaret S. Rigg, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined an $81,679 income tax deficiency for petitioner's tax year ended May 31, 1993, a $6,082 section 6651(a)(1)1 addition to tax, and a $16,366 section 6662 penalty.

The issues for our consideration are: (1) Whether litigation costs paid by petitioner on behalf of clients and then reimbursed to petitioner are deductible as ordinary and necessary business...

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