Memorandum Opinion
WOLFE, Special Trial Judge:
Respondent determined a deficiency of $3,398.00 in petitioners' Federal income taxes for 1980 and additions to tax of $170.00 under section 6653(a).
After concessions, the sole issue for our decision is whether petitioners are entitled to deduct legal expenses incurred in 1980.
This case was submitted fully stipulated pursuant to Rule 122. The stipulation of facts...
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