Opinion
No. 13951.
Argued December 10, 1962.
Decided December 28, 1962.
On petition for review of the decision of the Tax Court of the United States.
George F. Shinehouse, Jr., Philadelphia, Pa. (Zink, Shinehouse Holmes, Philadelphia, Pa., on the brief), for petitioners.
Earl J. Silbert, Dept. of Justice, Washington, D.C., (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Robert N. Anderson, Attys., Dept. of Justice, Washington, D.C., on the brief), for respondent.
Before KALODNER and FORMAN, Circuit Judges, and ROSENBERG, District Judge.
Upon review of the record we find no error in the holding of the Tax Court that the payment made by the petitioners (taxpayers) in compromise of litigation was not a deductible expense under either Section 162 or Section 212 of the Internal Revenue Code of 1954.
The Decision of the Tax Court will be affirmed.