Higgins v. Commissioner of Internal Revenue

MAHONEY, Circuit Judge.

In his income tax return for the calendar year 1939, the taxpayer deducted the sum of $4,666.48 for “services rendered in connection with management, preservation and conservation of property”. According to the stipulation of facts filed by the parties, $3,794.13 of this amount represented fees paid to attorneys for services and advice and $892.34 represented a bookkeeper’s salary. The amount of. the attorneys’ fees consisting of the sum of $2,544.-13 paid in connection with problems relating to the management and investment of property of the taxpayer, was allowed by…