DAWSON, Judge:
Respondent determined a deficiency in petitioners' 1976 Federal income tax in the amount of $3,735. The deficiency stems from the disallowance of a $10,075 fee paid by Robert Nicolazzi during 1976 to Melbourne Concept, Inc., a company engaged in the business of procuring noncompetitive Federal oil and gas leases on behalf of its clients. The following issues are presented for decision:
(1) Whether any portion of the $10,075 fee is deductible...
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