“origins” in each of Dye’s legal claims. Where, as here, the litigation involves more than one claim, “[t]he origin [of the claim] test must be applied separately to each part.” Dolese v. United States, 605 F.2d 1146, 1151 (10th Cir.1979), cert. denied, 445 U.S. 961, 100 S.Ct. 1647, 64 L.Ed.2d 236 (1980). Legal fees, like other expenses, may, under certain circumstances, be partially deductible and partially nondeductible. See, e.g., Treas. Reg. § 1.212-l(k) (“Attorneys’ fees paid in a suit to quiet title to lands are not deductible; but if the suit is also to collect accrued rents thereon, that portion of such fees is deductible which is properly allocable to the services rendered in collecting such rents.”); see also Boagni v. Commissioner, 59 T.C. 708, 713-14, 1973 WL 2589 (1973) (<HOLDING>). Consequently, when litigation originates in
recognizing that legal expenses incurred can be characterized as both deductible and nondeductible when the litigation is rooted in situations giving rise to both types of expenditures holding attorney fees may be allowed for expenses incurred for default holding that an award for medical expenses is proper when the expenses have been incurred but not paid holding defense applicable to both types of claims holding that medical expenses must be proven to be both reasonable and necessary