Alec Jeffrey Megibow - Page 2

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                                        MEMORANDUM OPINION                                              
                  HALPERN, Judge:                                                                       
            I.  Introduction                                                                            
                  By notice of deficiency dated July 18, 1996, respondent                               
            determined a deficiency in petitioner’s 1993 Federal income tax                             
            of $48,275 and an accuracy-related penalty in the amount of                                 
            $9,655.                                                                                     
                  Each party has conceded certain issues and the issues                                 
            remaining for decision are (1) the deductibility of $50,000                                 
            claimed by petitioner as an alimony payment, (2) the                                        
            deductibility of $48,651.75 claimed by petitioner as business-                              
            related legal fees, (3) whether petitioner must include in gross                            
            income $30,000 received by him from Radiology Affiliates of NY,                             
            and (4) whether any underpayment is due to petitioner’s                                     
            negligence or disregard of rules or regulations.                                            
                  Unless otherwise indicated, all section references are to                             
            the Internal Revenue Code in effect for the year in issue, and                              
            all Rule references are to the Tax Court Rules of Practice and                              
            Procedure.                                                                                  
                  Certain facts have been stipulated.  The stipulation of                               
            facts filed by the parties, with attached exhibits, is                                      
            incorporated herein by this reference.  We have need to find few                            
            facts in addition to those stipulated and, accordingly, shall not                           
            separately set forth those findings.  We include our additional                             






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