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Petitioner also claimed $1,350 in professional and legal
fees, consisting of $1,000 in legal and accounting fees paid for
business document review and preparation of petitioners’ tax
return and $350 in legal fees paid for the preparation and filing
of a Plea of Abatement regarding property taxes. These fees are
deductible under section 212(3) as they are “in connection with
the determination, collection, or refund of any tax”, but they
are only deductible as a miscellaneous itemized deduction to the
extent the aggregate of such deductions exceeds 2 percent of
adjusted gross income pursuant to section 67.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011