Andrew S. and Linda Hayworth Brenner - Page 21

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          attributable to 1997) as a miscellaneous itemized deduction on              
          their 1997 return as filed.  Sec. 1.62-2(c)(5), Income Tax Regs.            
          III.  Conclusion                                                            
               We hold that petitioners’ deduction of $215,354 for legal              
          fees for 1997 was properly reported as a miscellaneous itemized             
          deduction on Schedule A of the original return, as filed, and               
          that respondent properly added that amount to reported taxable              
          income in his computation of petitioners’ 1997 alternative                  
          minimum tax.  We, therefore, sustain respondent’s deficiency                
          determination.                                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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