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EMMANUEL v. COMMISSIONER

Docket No. 56727.

28 T.C. 1305 (1957)

SAM EMMANUEL AND WINIFRED EMMANUEL, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 30, 1957.

Attorney(s) appearing for the Case

Harold A. Pebbles, Esq., and C. L. Stickney, C. P. A., for the petitioners.

John O. Durkan, Esq., for the respondent.

TIETJENS, Judge:

The Commissioner determined deficiencies in income tax in the amounts of $768.26, $583.24, and $188.42 for the respective years 1949, 1950, and 1951.

The only question for decision is the deductibility in 1952 of legal fees purported to have been paid in that year by two assignments of cash bail on deposit in court in connection with pending criminal litigation against Sam Emmanuel. The year...

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