Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined a deficiency in petitioners' 1983 Federal income tax in the amount of $910. The issue for decision is what portion, if any, of a legal fee paid by petitioners for estate planning services is deductible under I.R.C. sections 162 or 212. (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for 1983. All Rule references are...
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