Hughes & Luce, L.L.P. v. Commissioner

WIENER, Circuit Judge.

This federal income tax case finds a law firm appealing from an adverse judgment rendered by the United States Tax Court. The underlying dispute arose when, during the course of an audit, the Internal Revenue Service (IRS) determined that “Service Costs” deducted by Hughes & Luce, L.L.P. should be treated as nondeductible loans to clients. The instant controversy concerns the collateral issue of the proper tax treatment of currently-received reimbursements of “Service Costs” previously deducted by the law firm as expenses in earlier tax years. The Tax Court upheld the…