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has identified neither the amount nor the nature of those
expenditures.
Deduction Under Section 216
Petitioner has failed to explain how section 216, Deduction
of Taxes, Interest, and Business Depreciation by Cooperative
Housing Corporation Tenant-Stockholder, has any application here.
The Court can find no legal or factual relevance of section 216
to this case.
The Court has considered the other arguments raised by
petitioner and has found them to be without merit.
Conclusion
Respondent's determination that petitioner is not entitled
to deduct legal expenses for 1997 and 1998 is sustained.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011