T.C. Memo. 2000-173
UNITED STATES TAX COURT
ARNOLD REISMAN AND ELLEN REISMAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18805-97. Filed May 25, 2000.
Arnold Reisman and Ellen Reisman, pro sese.
Marc A. Shapiro, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined a deficiency of $117,567
in petitioners’ joint 1994 Federal income tax.
The only issue for decision1 is whether a $350,000 payment
1Petitioners paid $38,533 in legal fees in 1994, which the
parties have stipulated will qualify as a miscellaneous expense
on Schedule A, Itemized Deductions, if this Court holds that the
(continued...)
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