John DiFronzo - Page 10

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          162(c),(f); Hawronsky v. Commissioner, 105 T.C. 94, 97-101                  
          (1995), affd. without published opinion 98  F.3d 1338 (5th Cir.             
          1996); Tippin v. Commissioner, 104 T.C. 518, 528 (1995); Zecchini           
          v. Commissioner, T.C. Memo. 1992-8, but the payment here of legal           
          expenses is no more illegal than the payment of rent or utility             
          charges.                                                                    
               To the extent that petitioner has established the payment of           
          the legal fee in question, we hold that he is entitled to the               
          claimed deduction.                                                          
                                             Decision will be entered                 
                                   under Rule 155.                                    



























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