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MERIANS v. COMMISSIONER

Docket No. 2358-71.

60 T.C. 187 (1973)

SIDNEY MERIANS AND SUSAN MERIANS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 8, 1973.

Attorney(s) appearing for the Case

Robert B. Hendler, for the petitioners.

Robert N. Ginsburg, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $1,136.32 in the petitioners' 1967 Federal income tax. The only issue for decision is whether the petitioners have shown what portion of a $2,144 attorney's fee was allocable to tax advice.

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so found.

The petitioners, Dr. Sidney Merians and Susan Merians, are husband and wife, who maintained their legal...

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