Paul Willard is a self-employed attorney.Because of erroneous advice that he gave, one of Paul's clients incurred unnecessary costs of $20,000.The client threatened to sue Paul for malpractice, and Paul reimbursed this sum to his client.Although his malpractice insurance would have covered the payment, he chose not to file for reimbursement.Because he had two recent malpractice claims, Paul is convinced that another claim could cause him to be either uninsurable or insurable only at unaffordable rates.

Issue:May Paul deduct the $20,000 reimbursement paid to his client?

answer the following questions:

1) Give a simple, nontechnical answer to the question posed

2) What is (are) the Code section(s) at issue?

3) Are any Treasury Regulations relevant?

4) List the case or Revenue Ruling authority