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SEIDLER v. COMMISSIONER

Docket No. 33558.

18 T.C. 256 (1952)

FREDERIC A. SEIDLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 12, 1952.

Attorney(s) appearing for the Case

David Beck, Esq., for the petitioner.

John J. Hopkins, Esq., for the respondent.

The respondent determined deficiencies in income taxes against the petitioner as follows:

Year                                                 Deficiency

1946 ---------------------------------------------    $474.68
1947 ---------------------------------------------   4,949.16

The issue in this proceeding is whether amounts expended in litigation and settlement of a controversy are deductible under the provisions of section 23 of...

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