MEMORANDUM OPINION
RAUM, Judge:
The Commissioner determined a $31,635 deficiency in petitioner's 1993 Federal income taxes. There are two issues for consideration: (1) Whether petitioner properly substantiated payment of $125,000 in legal fees to his attorney, and (2) whether those fees, which were paid to defend petitioner, unsuccessfully, against charges of conspiracy and mail and wire fraud, are, to the extent substantiated, deductible as ordinary and...
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