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number of issues raised in the pleadings, and the amount of money
involved in the respective issues, the management of the Chicago
rental property appears to have been a minor issue. Under the
circumstances of this case, an "allocation of any portion of the
[payments] to a section 212(2) purpose would be speculative,
amounting to `unguided largesse.'" Luman v. Commissioner, supra
at 859 and cases cited therein.
Based on the entire record in this case we find that
petitioners may not deduct any portion of their expenditures for
attorney's fees in the years 1990, 1991, and 1992.
Decision will be entered for
respondent.
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Last modified: May 25, 2011