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PHILIP T. v. COMMISSIONER

Dkt. No. 9354-05.

93 T.C.M. 991 (2007)

T.C. Memo. 2007-58

Philip T. and Mary Ellen Chaplin v. Commissioner.

United States Tax Court.

March 12, 2007.

Attorney(s) appearing for the Case

David R. Andelman and Juliette Galicia Pico, for petitioners.

Nina P. Ching, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HAINES, Judge:

Respondent determined a deficiency in petitioners' 2001 Federal income tax of $24,185 and an accuracy-related penalty under section 6662(a) of $4,837.1 The issues for decision are: (1) Whether petitioners are entitled to deduct legal fees of $84,542 from their adjusted gross income pursuant to section 62(a)(1), or whether petitioners must deduct the legal fees as a miscellaneous...

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