PER CURIAM.
This case having been considered by the Court on the record, briefs and oral argument on behalf of the respective parties;
And the Court being of the opinion that the ruling of the Tax Court that the $2,700 paid by petitioners for the purpose of protecting and perfecting the title to real estate in which the petitioners had an interest was a capital expenditure and not a deductible expense for income tax purposes under Section 23 (a) (1) or (2...
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