James E. Caldwell & Company v. Commissioner of Internal Revenue

This is a petition to review a decision of the Tax Court. At issue in that court were three essentially unrelated questions: “1. Whether the Commissioner correctly determined that petitioner could not capitalize the cost of settling a suit which represented a cloud on its title to certain real property. 2. Whether the Commissioner correctly determined that petitioner could not deduct a payment in satisfaction of its share of a tort judgment and related attorney’s fees. 3. Whether the Commissioner correctly determined that petitioner realized gain to the extent of the full sale price of…