PER CURIAM:
Taxpayers appeal a Tax Court judgment denying a deduction of $22,000 as an ordinary business expense. The expense came when the taxpayers sold their loan business and then paid $20,000 to the purchaser and $2,000 in attorney fees for a release from their warranty liability on certain outstanding loans.
While the Tax Court correctly treated the $20,000 payment as an attempt to salvage capital, the $2,000 attorney fee was not so clearly a capital...
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