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ROCKWELL v. COMMISSIONER

Docket No. 83566.

37 T.C. 246 (1961)

HENRY M. ROCKWELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 21, 1961.

Attorney(s) appearing for the Case

Wright Matthews, Esq., for the petitioner.

George Voss, Esq., for the respondent.

Respondent has determined a deficiency in the income tax of petitioner for the year 1956 in the amount of $29,317.17. The adjustment giving rise to the deficiency is "(a) Legal expenses $34,502.11" and is explained in the statutory notice as follows:

(a) It has been determined that legal fees and other expenditures in the amount of $34,502.11 deducted on your return as ordinary and necessary expenses for the conservation of...

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