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DRAPER v. COMMISSIONER

Docket No. 51111.

26 T.C. 201 (1956)

PAUL AND HEIDI DRAPER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1956.

Attorney(s) appearing for the Case

Charles N. Schenck, III, Esq., for the petitioners.

John J. O'Toole, Esq., for the respondent.

Petitioners contest deficiencies of $3,441.68 and $311.44 in income taxes determined for the calendar years 1947 and 1949, respectively. No part of a 1948 deficiency is in dispute. Respondent disallowed a deduction in 1949 of legal expenses, which had in part resulted in a loss carryback to 1947. The only issue presented is the deductibility of legal expenses paid by petitioners to prosecute a libel action.

FINDINGS OF FACT...

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