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ARMOUR v. COMMISSIONER

Docket No. 4471.

6 T.C. 359 (1946)

PHILIP D. ARMOUR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 7, 1946.

Attorney(s) appearing for the Case

Harry D. Orr, Jr., Esq., for the petitioner.

Harold H. Hart, Esq., for the respondent.

This proceeding involves a redetermination of petitioner's income tax liability for 1940. The Commissioner has determined that there is a deficiency of $9,421.22.

Two questions are raised: (1) Whether petitioner is entitled to a deduction for an interest payment made by him in the taxable year on a tax deficiency assessed against him as transferee, and (2) whether certain legal fees paid by him in connection with the contest...

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