Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $359.23 in petitioners' Federal income tax for the taxable year 1966.
The issues present for our consideration are:
(1) whether the doctrine of collateral estoppel is applicable to preclude petitioners from litigating the issue of the deductibility of petitioner Ronald F. Weiszmann's educational expenses incurred in attending law school during the taxable...
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