Baylin v. United States

OPINION

YOCK, Judge.

This tax case is before the Court on cross-motions for summary judgment pursuant to RCFC 56. In this action, Mr. Jack Baylin, the tax matters partner of the Painters Mill Venture (“plaintiff’ or the “Partnership”),1 has moved for summary judgment seeking readjustment of partnership items as set forth in the Internal Revenue Service’s (“IRS”) notice of Final Partnership Administrative Adjustment (FPAA).2 The plaintiff *250alleges that a portion of the attorney’s fees it incurred in a condemnation proceeding were properly deductible as “ordinary and necessary expenditures” in…