- 121 - H. Claimed Deductions for Legal and Professional Fees In 1975 petitioner paid DuBois Jansson $2,907.34 for services rendered with respect to acquiring railroad equipment that would be sold to the Iranian State Railway. Petitioner deducted this amount on his 1975 Federal income tax return. On his tax returns and in his books and records for the years 1973 through 1977 petitioner took the position that the income from only 40 percent of the products sold to Iranian State Railways was taxable to him. Petitioner contends that the income from the remaining 60 percent of the products sold constituted income of Diesel Power. Because we have found that all of the income was petitioner's, he is entitled to deduct professional fees of $2,907.34 paid to DuBois Jansson for 1975. During the years 1976, 1977, and 1978 petitioner deducted legal fees paid to the law firm of George, Greek, King, McMahon & McConnaughey in amounts that were at least $57,921.08, $57,419.26, and $25,059.21, respectively. These fees were paid for a variety of services, including acquisitions of real estate, matters involving the Harris Corporation, handling the arbitration of a dispute between Clark and Diesel Power, handling a home purchase matter for petitioner's brother, Monty Zand, landlord-tenant issues, research concerning joint ventures, matters involving insurance and pension plans, tax matters, preparations of a will and trust, and a number of conferencesPage: Previous 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 Next
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