T.C. Memo. 2000-362
UNITED STATES TAX COURT
ERIC TEST AND ODELIA BRAUN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4907-99. Filed November 27, 2000.
Karen L. Hawkins, for petitioners.
G. Michelle Ferreira, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $24,647 deficiency in
petitioners’ 1994 Federal income tax and a $4,929 accuracy-
related penalty pursuant to section 6662(a).1 The issues for our
consideration are: (1) Whether legal fees incurred by
1 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.
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