State Fish Corp. v. Commissioner

SUPPLEMENTAL OPINION

Forrester, Judge:

This proceeding is before us on respondent’s motions. In our opinion in this case, entered June 28, 1967 (48 T.C. 465), we held, inter alia, that the receipt of $93.36 as reimbursement of court costs expended by petitioner for the recovery of taxable interest was not taxable to it because the receipt was simple a prorata reimbursement of costs which had been paid by petitioner. We further held that the court costs and legal fees expended by petitioner for the recovery of taxable interest were allowable as a deduction in the year in issue. Respondent reads…