- 223 - 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 reallocablePage: Previous 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 Next
Last modified: May 25, 2011