Sharples v. United States

In this income tax refund suit plaintiff seeks a 1966 deduction for legal expenses incurred while resisting a Venezuelan tax deficiency. The potential Venezuelan tax liability devolved on plaintiff as the recipient of assets from a liquidated corporation that would have incurred the tax. The issue comes before the court for resolution based upon the parties’ stipulation of facts pursuant to Ct. Cl. Rule 134(b) (2). We *512hold that plaintiff is entitled to deduct the 'legal expenses under the provisions of subsection 212(3) of the Internal Revenue Code of 1954.1

As stipulated, Philip Sharpies…