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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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