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BOAGNI v. COMMISSIONER

Docket No. 4969-71.

59 T.C. 708 (1973)

VINCENT BOAGNI, JR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 28, 1973.

Attorney(s) appearing for the Case

John S. Dowling, for the petitioner.

A.A. Simpson, Jr., for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the income tax of Vincent Boagni, Jr., for 1968 in the amount of $10,813.86. The only issue for decision is whether petitioner may deduct, under section 212,1 legal fees incurred in two court proceedings, one a declaratory judgment action in which petitioner's title to an overriding royalty interest was placed in dispute and the other involving a claim to...

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