- 10 - contravening respondent’s determinations as to the other adjustments in the notices of deficiency. We see no reason to reiterate each adjustment nor the reason that we sustain each adjustment. The one exception to this concerns the legal fees deducted in 1998. It is clear that petitioner retained John R. McCabe, an attorney, to represent her with respect to the determination of the value of the property purchased by the Corps. That value had a direct impact on the amount of income that she recognized during 1997. Furthermore, from the correspondence in the record it would appear that the amount of fees deducted ($500) was reasonable for the services performed. We find, therefore, that petitioners are entitled to a deduction of $500 for legal fees under section 212(3). Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent for the taxable year 1997 at docket No. 8191-00S, and decision will be entered under Rule 155 for the taxable year 1998 at docket No. 10437-01S.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011