Memorandum Opinion
TIETJENS, Judge:
Respondent determined a deficiency of $2,438 in petitioner's Federal income tax for 1975. The sole issue for decision is whether amounts paid as legal fees from an action to quiet title on certain property are deductible.
This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached exhibits are incorporated herein by reference.
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