BLUMENTHAL v. COMMISSIONER OF INTERNAL REVENUE, 334 F.2d 281 (4th Cir. 1964)
I.D. BLUMENTHAL and Madolyn C. Blumenthal, Petitioners, v. COMMISSIONER OFINTERNAL REVENUE, Respondent.
No. 9397.United States Court of Appeals, Fourth Circuit.Argued June 16, 1964.
Decided June 17, 1964.
Richard E. Thigpen, Jr., Charlotte, S.C. (Richard E. Thigpen and Robert L. Hines, Charlotte, N.C. on brief), for petitioners
C. Guy Tadlock, Atty, Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., and Lee A. Jackson and Meyer Rothwacks, Attys, Dept. of Justice, on brief), for respondent.
Before SOBELOFF, Chief Judge, HAYNSWORTH, Circuit Judge, and MICHIE, District Judge.
PER CURIAM.
The Tax Court held that the legal expenses which the taxpayer sought to deduct were not ordinary and necessary business expenses deductible under ยง 212 of the Internal Revenue Code of 1954. For the reasons stated by the Tax Court in its opinion,[fn*] we agree that these were capital disbursements.
Affirmed.
[fn*] T.C. Memo 1963-269.Page 296