John DiFronzo - Page 1

                                 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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