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incurred with respect to the purchases and sales of real estate,
the joint ventures, the fees concerning Harris Corporation if
they dealt with a long-term contract for services, and the
corporate liquidation are capital expenditures rather than
ordinary and necessary business expenses. See Collins v.
Commissioner, 54 T.C. 1656 (1970); Bilar Tool & Die Corp. v.
Commissioner, 530 F.2d 708 (6th Cir. 1976). Furthermore, the
legal fees petitioner incurred with respect to insurance and
pension matters are his personal expenses rather than ordinary
and necessary business expenses. In contrast, respondent agrees
that any fees incurred for tax matters and landlord-tenant
problems are petitioner's ordinary and necessary business
expenses. Finally, as will be discussed in more detail below,
the fees paid in the arbitration between Clark Equipment and
Diesel Power are the expenses of Diesel Power, and not those of
petitioner. The payments to George, Greek pertaining to the
Clark arbitration involving Diesel Power were specifically set
forth as $20,607.58, $17,950.59, and $6,315.68 for the years
1976, 1977, and 1978, respectively.
Thus, petitioner's legal expenses include both deductible
and nondeductible items. Problematically, petitioner's
supporting documentation, the law firm bills, lacks the requisite
specificity to demonstrate what amount of the fees is reallocable
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