T.C. Memo. 2002-57
UNITED STATES TAX COURT
INTEREX, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17030-99. Filed February 27, 2002.
Paul J. Dee, Jr., for petitioner.
Carina J. Campobasso, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined a deficiency of $67,473
in petitioner’s Federal income taxes for 1994 and a penalty of
$5,070 under section 6662. After concessions, the issues for
decision are whether petitioner is entitled to a deduction for
professional fees in the amount of $65,000 for 1994 and whether
petitioner is liable for the penalty. Unless otherwise
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