Michael Forbes Dehoney - Page 1

                                 T.C. Memo. 2006-108                                  

                               UNITED STATES TAX COURT                                

                        MICHAEL FORBES DEHONEY, Petitioner v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3305-04.             Filed May 16, 2006.                    

               Michael Forbes Dehoney, pro se.                                        
               Jeanne Gramling, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               WELLS, Judge:  Respondent determined a $743 deficiency in              
          income tax for petitioner’s taxable year 2001.  After                       
          concessions, the only issue remaining is whether petitioner is              
          entitled to deduct for taxable year 2001 certain legal expenses             
          that were paid in taxable year 2002.  Unless otherwise indicated,           
          all section references are to the Internal Revenue Code, as                 

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