Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated March 24, 1981, respondent determined deficiencies in petitioners' Federal income taxes for the taxable years ended December 31, 1977 and December 31, 1978 in the amounts of $12,349.09 and $16,533.02, respectively. The sole issue before the Court is whether litigation costs paid by petitioners are deductible expenses or capital expenditures.
Findings of Fact<...
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