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KELLY v. COMMISSIONER

Docket No. 750-97.

77 T.C.M. 1501 (1999)

T.C. Memo. 1999-69

Daniel Francis Kelly, Jr. v. Commissioner.

United States Tax Court.

Filed March 8, 1999.

Attorney(s) appearing for the Case

Timothy F. Kelly, for the petitioner. Ann M. Welhaf, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182.

Respondent determined deficiencies of $3,850 and $1,063 in petitioner's Federal income taxes for 1991 and 1992, respectively.

The sole issue for decision is whether, for 1991 and 1992, petitioner is entitled to deduct, under section 162(a), as trade or business expenses, legal expenses...

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