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BIEHL v. COMMISSIONER

Docket No. 422-00.

118 T.C. 467 (2002)

118 T.C. No. 29

FRANK AND BARBARA BIEHL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 30, 2002.

Attorney(s) appearing for the Case

David M. Kirsch, for petitioners.

Julie A. Fields, for respondent.

OPINION

BEGHE, Judge:

This case is before the Court fully stipulated under Rule 122.1 Respondent determined a deficiency of $97,833 in petitioners' 1996 Federal income tax. The issue for decision is whether petitioners may treat a certain attorney's fee as paid under "a reimbursement or other expense allowance arrangement" as defined in section 62(a)(2)(A) and (c) so as to be excluded from gross income or deducted in arriving...

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