Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $57,441 in petitioners' Federal income tax for the year ended December 31, 1989.
The sole issue for decision is the proper treatment for legal fees that J. Kenneth Alexander (petitioner) paid in connection with the settlement of a civil lawsuit that he filed against his former employer.
Unless otherwise indicated, all section references are to the...
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