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LOEW v. COMMISSIONER

Docket No. 29639.

17 T.C. 1347 (1952)

ALFRED J. LOEW, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 15, 1952.

Attorney(s) appearing for the Case

Alfred J. Loew, pro se.

William G. O'Neill, Esq., for the respondent.

Petitioner by this proceeding brings in question respondent's determination of a deficiency in income tax for the year 1944 in the amount of $904.07. The deficiency results from respondent's determination that legal fees in the amount of $3,500 received by petitioner as attorney for the estate of a decedent in the taxable year were not subject to section 107 (a), Internal Revenue Code.

FINDINGS OF FACT.

Some of...

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