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incurred in connection with the operation of the cattle ranch are
deductible as administration expenses under section 2053.9
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
9 Consistent with respondent's argument that the expenses of
operating the ranch are not deductible, respondent has also
argued that the portion of legal fees and accounting fees paid to
Mr. Lanier and an accounting firm that were attributable to the
operation of the ranch are not deductible as administration
expenses. Respondent's argument explicitly rests on the
assumption that the expenses incurred in the operation of the
cattle ranch, in general, are not deductible as administration
expenses. Because we hold that the expenses incurred in the
operation of the ranch are deductible as administration expenses
under sec. 2053, the legal and accounting fees relating to the
operation of the ranch are likewise deductible as administration
expenses.
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