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ERIC TEST v. COMMISSIONER

Docket No. 4907-99.

80 T.C.M. 766 (2000)

T.C. Memo. 2000-362

Eric Test and Odelia Braun v. Commissioner.

United States Tax Court.

Filed November 27, 2000.

Attorney(s) appearing for the Case

Karen L. Hawkins, for the petitioners. G. Michelle Ferreira, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

GERBER, Judge:

Respondent determined a $24,647 deficiency in petitioners' 1994 Federal income tax and a $4,929 accuracy-related penalty pursuant to section 6662(a).1 The issues for our consideration are: (1) Whether legal fees incurred by petitioners are deductible as Schedule C business expenses or as Schedule A miscellaneous itemized deductions, and (2) whether petitioners are liable...

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