OPINION
DAWSON, Chief Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1971 and 1972 in the amounts of $912.36 and $2,195.68, respectively. The only issue presented for decision is whether payments made by petitioner to settle an action under section 12(1) of the Securities Act of 1933, 15 U.S.C. sec. 77l(1)(1970), are so directly related to a sale of unregistered stock in a prior tax year...
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