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E. Legal and Professional Fees
Petitioner claimed a deduction for the amount of $2,097.34
on his 1975 Federal income tax return. The deduction claimed was
for a payment to DuBois Jansson for Mr. Jansson's services in
connection with products to be sold to Iranian State Railways.
Because we have previously held that petitioner is taxable on the
income from the sales to Iranian State Railways, he is entitled
to deduct the $2,097.34 paid to Mr. Jansson
Respondent disallowed legal fees paid to George, Greek,
King, McMahon & McConnaughey, a Columbus, Ohio, law firm in the
amounts of $57,921.08 in 1976, $57,419.26 in 1977, and $25,059.21
in 1978. Petitioner offered a variety of bills from the law firm
in support of the business purpose of these fees. However, the
bills do not itemize the particular services rendered, the time
spent for particular services, and the corresponding charge.
Instead, they list the general nature of the matter for which
services were rendered. Included in the services rendered are
acquisition of real estate, conferences concerning Harris
Corporation, work on the Clark arbitration matter, drafting
leases, a dispute involving property purchased, services
concerning joint ventures, a corporate liquidation, conferences
with representatives of insurance companies on insurance and
pension matters, and tax issues. The legal fees petitioner
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