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COUGHLIN v. COMMISSIONER

Docket No. 822.

3 T.C. 420 (1944)

JAMES C. COUGHLIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 7, 1944.

Attorney(s) appearing for the Case

N. A. Eisner, Esq., for the petitioner.

T. M. Mather, Esq., for the respondent.

This proceeding is for the redetermination of a deficiency in income tax for the year 1941 in the amount of $2,075.22. The question is whether an expenditure of $4,000 for legal fees is a deductible expense under section 23 (a) of the Internal Revenue Code, as amended by section 121 of the Revenue Act of 1942.

FINDINGS OF FACT.

The petitioner, James C. Coughlin, is an individual residing in San Francisco, California...

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