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THOMAS v. COMMISSIONER

Docket No. 93556.

41 T.C. 614 (1964)

CLYDE E. THOMAS, SR., AND REBA E. THOMAS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 12, 1964.

Attorney(s) appearing for the Case

Julius C. Calhoun, for the petitioners.

Bruce Hallmark, for the respondent.

OPINION

BRUCE, Judge:

Respondent determined a deficiency in the income tax of petitioners for the taxable year 1959 in the amount of $150. The sole issue is whether a legal fee paid by petitioners in connection with the settlement of their disputed Federal income tax liabilities for prior years is deductible in computing adjusted gross income under section 62(1) of the Internal Revenue Code of 19541 for the year 1959....

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