What is the difference between a net fee contract and a gross fee contract?

With some clients the firm had a "net fee contract" where the firm explicitly agreed "to pay all costs," and the client agreed that all such costs should be repaid only out of the recovery. The costs paid under the net fee contract were held to be nondeductible in Boccardo v. United States, 12 Cl.Ct. 184 (1987). Well before this decision, the firm's tax counsel had recommended "the gross fee contract" as the advisable way of securing the deduction of the costs as ordinary and necessary business expenses.