MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
Respondent determined a deficiency of $17,047.96 in petitioners' 1992 Federal income tax. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are whether petitioners' expenditures for legal services, which respondent agrees...
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