Keith T. and Geraldine A. Bowers - Page 11

                                       - 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