Revenue Ruling 77-254
Internal Revenue Service
1977-2 C.B. 63 (1977)
Facts
The taxpayer (plaintiff), described as an individual taxpayer, incurred various costs, such as for travel and advertising, while searching for a business to purchase. The taxpayer eventually decided on a business to purchase and incurred legal fees to draw up the purchase agreement. However, the purchase fell through. The taxpayer sought to deduct all the costs of travel, advertising, and legal fees. The commissioner of Internal Revenue (defendant) disagreed and disallowed the deductions of travel and advertising, but the commissioner allowed deductions of the legal fees incurred in drafting the purchase agreement for the specific business that the taxpayer tried unsuccessfully to purchase.
Rule of Law
Issue
Holding and Reasoning ()
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