Gerry M. Griggs - Page 5

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          merchant banker.  In 1985, petitioner was employed by Advanced              
          Energy Technologies (AET) as vice president and chief financial             
          officer (CFO).  He was also on the board of directors of AET                
          until January 1989.  AET terminated petitioner from his position            
          as CFO in September 1988.  In May 1989, petitioner returned to              
          AET as CFO and was again terminated in January 1990.                        
               The first issue is petitioner’s claim to Schedule A                    
          deductions of $11,981.54 for miscellaneous legal expenses.                  
          Petitioner paid legal fees in connection with litigation against            
          his former employer, AET, for breach of his employment contract             
          and for the recovery of retirement benefits.  Petitioner also               
          paid legal fees in connection with litigation against two other             
          corporations over the purchase of certain film rights and assets.           
          Another legal action involved a malpractice claim against one of            
          his former attorneys.                                                       
               Of the $11,981.54 claimed by petitioner for miscellaneous              
          legal expenses on Schedule A of his return, respondent concedes             
          petitioner’s entitlement to a deduction of $5,000 for legal                 
          expenses, leaving at issue $6,981.54.                                       
               Based on the evidence presented at trial, the Court is                 
          satisfied that petitioner is entitled to an additional deduction            
          of $5,501.86 for legal expenses.  This consists of $3,000, which            
          is shown as a credit on a statement presented at trial from one             
          of the law firms that represented petitioner, and $2,501.86,                






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