Allied Chemical Corp. v. United States

Plaintiff sues for a refund of excess profits and income taxes paid for the years 1945, 1946 and 1947. Two issues presented are: first, whether attorneys’ fees paid in 1945, 1946 and 1947, in opposing certain proceedings brought *269by the Securities and Exchange Commission (hereinafter, S.E.C.) were deductible as “ordinary and necessary expenses in carrying on a trade or business”, or as capital expenditures incurred in the realization of a capital gain; and second, whether a loss incurred in 1946 on certain notes and participation certificates is deductible as a bad debt, or as worthless…