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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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Last modified: November 10, 2007