M.H. Bell and Bettie Lou Bell v. Commissioner of Internal Revenue

VOGEL, Circuit Judge.

The petitioners, who are husband and wife, brought this suit in the Tax Court for redetermination of an alleged deficiency in their income tax for the year 1952 in the amount of $1,929.02. Petitioners seek to deduct as a business expense certain attorney’s fees paid in the taxable year of 1952.

Petitioner Marion H. Bell, the husband, was and is a certified public accountant. During the taxable year in question he was practicing at Fort Smith, Arkansas. In late 1951 he was notified by the Internal Revenue Service that his tax returns for the years 1945 through 1949 were…