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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.
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