MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined an $81,679 income tax deficiency for petitioner's tax year ended May 31, 1993, a $6,082 section 6651(a)(1)
The issues for our consideration are: (1) Whether litigation costs paid by petitioner on behalf of clients and then reimbursed to petitioner are deductible as ordinary and necessary business...
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