MEMORANDUM OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income tax for the years 1990, 1991, and 1992 in the amounts of $1,358, $4,209, and $2,072, respectively. The sole issue for decision is whether petitioners are entitled to deductions under section 212 for legal fees paid...
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