Stephen F. Scofield and Nancy E. Scofield - Page 3

               (2)  Whether petitioners may deduct legal expenses of                  
          $10,243 in 1986, $59,352 in 1987, and $104,156 in 1988.  We hold            
          that they may, subject to the 2-percent limit in section 67.                
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
                                I.  FINDINGS OF FACT                                  
               Some of the facts have been stipulated and are so found.               
          A.   Petitioners                                                            
               Petitioners Stephen F. Scofield (petitioner) and Nancy E.              
          Scofield (Mrs. Scofield) are married and lived in Marietta,                 
          Georgia, when they filed their petition.  Petitioners have been             
          married since 1981 and have four sons.                                      
               Petitioner graduated from Syracuse University in 1968 with a           
          degree in economics.  He started to work in the newsprint                   
          industry that year.  He worked for Great Northern Paper Co.                 
          (Great Northern) from 1968 to June 1972, primarily in sales                 
          positions.  Petitioner then worked for about 4 years as sales               
          manager for Eastern Color Printing Co. (ECP), a printing                    
          B.   Petitioner's Businesses                                                
               1.   Unidyne                                                           
               Petitioner left ECP around 1976 to start a company which he            
          named Unidyne, Inc. (Unidyne).  Unidyne was in the paper                    

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