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bulletin Internal Revenue›Rev. Proc. 90-63, 1990-2 C.B. 664, is

SECTION 1. TRADE OR

Internal Revenue Bulletin 1997-33 · 2026-10-03 edition · updated 2026-10-04 · United States

BUSINESS EXPENSES (§ 162)

.01 Advances made by a lawyer on be- half of clients — Description of change and scope. This change applies to a lawyer handling cases on a contingent fee basis that advances money to pay for costs of litigation or for other expenses on behalf of clients and that wants to change the method of accounting for such advances from treating them as deductible business expenses to treating them as loans. See Boccardo v. United States, 12 Cl. Ct. 184 (1987); Canelo v. Commis- sioner, 53 T.C. 217 (1969), aff’d per cu- riam, 447 F.2d 484 (9th Cir. 1971).

.02 Reserved.

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▸Contents — Internal Revenue Bulletin 1997-33

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