T.C. Memo. 1998-41
UNITED STATES TAX COURT
JOHN DIFRONZO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18476-96. Filed February 4, 1998.
Carl M. Walsh, for petitioner.
Warren M. Joseph and Donna C. Hansberry, for respondent.
MEMORANDUM OPINION
RAUM, Judge: The Commissioner determined a $31,635
deficiency in petitioner's 1993 Federal income taxes. There are
two issues for consideration: (1) Whether petitioner properly
substantiated payment of $125,000 in legal fees to his attorney,
and (2) whether those fees, which were paid to defend petitioner,
unsuccessfully, against charges of conspiracy and mail and wire
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