Pennell v. Commissioner
1926 BTA LEXIS 2100 | B.T.A. | 1926
Lead Opinion
OPINION.
The payment by an individual for general personal legal services, including the preparation of a will, are obviously not “ordinary and necessary expenses paid or incurred in the taxable year in carrying on any trade or business,” as provided in section 214(a) (1) of the Revenue Act of 1918. If any part thereof could be so classified the burden of allocation must be on the petitioner and not on the Board. We need not therefore discuss the question whether, since the payment of the entire bill of $20,000 was equally
Judgment for the Commissioner.