Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for 1982 in the amount of $56,148 and for 1983 in the amount of $125,717.
The parties submitted a stipulation of settled issues which disposed of all but one issue. The issue remaining for decision is whether litigation costs advanced on behalf of clients by the law firm in which petitioner James F. Boccardo (Mr. Boccardo)...
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