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deductible in 2001 because they were associated with his 2001 tax
return. We agree with respondent. Petitioner incurred and paid
the legal expenses in issue during his taxable year 2002.
Accordingly, petitioner must deduct these expenses in the year
paid, not in any prior year.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011