Treas. Reg. Sec. 1.213-1(e)(1)(ii) provided that taxpayer was not entitled to deduction for illegal treatment. Payments by tax attorney to various prostitutes in New York were personal expenses not prescribed by doctor and not intended to treat a medical condition. He was not entitled to deductions for these amounts. IRC Sec. 6662 penalty was upheld.

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LEXIS.com subscribers can view a complete discussion of relevant IRC Code and regulatory authority at Lexis Explanation IRC Sec. 6662(a), LexisNexis Tax Advisor -- Federal Topical § 5A:16.04, LexisNexis Tax Advisor -- Federal Topical § 1D:19.02 and 2-75 FEDERAL TAX GUIDEBOOK § 75.02.

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