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BUTLER v. COMMISSIONER

Docket No. 28368.

17 T.C. 675 (1951)

WILLIAM L. BUTLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 11, 1951.

Attorney(s) appearing for the Case

Andrew B. Young, Esq., and David P. Brown, Esq., for the petitioner.

Stanley W. Herzfeld, Esq., for the respondent.

The respondent determined a deficiency in income tax for the taxable year 1946 in the amount of $6,071.38.

The issues are: (1) whether $9,976.50 paid by the petitioner in settlement of a claim is deductible, and (2) whether legal expenses in the amount of $718.77 incurred in such settlement are deductible.

Some of the facts were stipulated.

FINDINGS OF FACT.

The stipulated facts are so found and are...

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