Silberman v. United States

OPINION

SMITH, Chief Judge.

I. INTRODUCTION

This case comes before the court on plaintiff’s motion for summary judgment and defendant’s cross motion for partial summary judgment. At issue is whether legal expenditures incurred by plaintiff, while defending himself against criminal charges of money laundering and in a parallel civil suit, are properly deductible as I.R.C. 162(a) business expenses on plaintiffs 1988 and 1989 federal income tax returns. Plaintiff claims that his legal fees are properly deductible under 162(a) and requests the court to grant summary judgment on that issue.…