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What is dispositive, however, is the fact that the legal expenses
in question arose out of an action to gain admission to the
California Bar. These costs are treated as bar admission
expenses and are, therefore, nondeductible under either section
162 or 212. Accordingly, petitioners are not entitled to their
claimed deduction.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011