Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for taxable year 1982 in the amount of $9,900 and an addition to tax for negligence which he since has conceded.
After concessions, the issues remaining for decision are: (1) whether petitioners may dispute the characterization of certain payments as payments for consulting services and, if so, (2) whether such payments were...
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