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Respondent determined deficiencies in petitioners' Federal
income tax for the years 1990, 1991, and 1992 in the amounts of
$1,358, $4,209, and $2,072, respectively. The sole issue for
decision is whether petitioners are entitled to deductions under
section 212 for legal fees paid during the years 1990, 1991, and
1992.
Most of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. At the time the petition in this case
was filed, petitioners resided in Tucson, Arizona. References to
petitioner are to M. Patricia Looby.
Background
In the statutory notice sent to petitioners in this case,
respondent disallowed for the years 1990 through 1992, itemized
deductions taken by petitioners for legal fees totaling
$29,915.07.2
The will
Petitioner's mother, M. Doris Casey (decedent), died leaving
a will on February 16, 1982. The will directed that debts,
funeral expenses, and the expenses of settling the estate be paid
by the executors as soon as practicable. The will made specific
2The parties stipulated petitioners' tax returns for 1990,
1991, and 1992, as well as the amounts of legal fees in each
year. In a separate paragraph the parties stipulated that the
fees for the 3 years totaled $30,095.07, an apparent error in
addition.
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