MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $67,473 in petitioner's Federal income taxes for 1994 and a penalty of $5,070 under section 6662. After concessions, the issues for decision are whether petitioner is entitled to a deduction for professional fees in the amount of $65,000 for 1994 and whether petitioner is liable for the penalty. Unless otherwise indicated, all section references are to the Internal...
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