22
colleagues, and we conclude that the payment of the legal fees
cannot reasonably be construed as being personal, as opposed to
business, in nature. Kornhauser v. United States, supra at 148.
The necessary elements having been met, we hold that Peters
is entitled to a deduction under section 212(1) for the
previously disallowed legal fees paid on his behalf by PGWV.
Decisions will be entered
under Rule 155.
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