Placid Oil Co. v. Internal Revenue Service (In Re Placid Oil Co.)

MEMORANDUM ORDER

FISH, District Judge.

This case is before the court on appeal from two orders of the bankruptcy court (1) determining that certain professional fees and expenses paid by the debt- or, Placid Oil Company (“Placid”), were nondeductible capital expenditures, and (2) disallowing Placid’s deduction of a loss claimed in connection with the sale of certain license rights. The bankruptcy court correctly held that the burden of proving that the professional fees were deductible current expenses was upon Placid as the taxpayer and that Placid failed to satisfy its burden of making this…