Robert J. Goldberg and Bradley A. Morgan - Page 12




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          concede that they are not entitled to the disputed deduction.               
          Such a concession does not deprive us of jurisdiction.  See LTV             
          Corp. v. Commissioner, 64 T.C. 589, 591 (1975).                             
               Thus, we conclude that we do have jurisdiction to                      
          redetermine petitioners’ deduction for legal, accounting,                   
          consulting, and advisory fees.  Therefore, respondent’s motion to           
          dismiss for lack of jurisdiction will be denied.                            
               To reflect the foregoing,                                              

                                             An appropriate order will be             
                                        issued.                                       





























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