T.C. Memo. 2002-173
UNITED STATES TAX COURT
JEFFREY AND KAREN WINTER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5432-00. Filed July 22, 2002.
Craig M. Hunt, for petitioners.
Kathryn K. Vetter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $40,092
in petitioners’ joint 1994 Federal income tax. The issue for
decision is whether petitioners may deduct or must capitalize
legal and consulting fees incurred in maintaining a lawsuit
against the seller of a hotel that they had previously purchased.
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