Is an HOA estoppel fee paid by the seller at closing an includable seller expense?

I've seen various opinions on HOA fees so I'm hoping some CPA/tax experts will chime in and put this question to rest...

Is an HOA estoppel fee that is part of the seller's closing costs an includable seller expense that can be used to reduce a gain on the sale?

The estoppel fee is common during closings involving a property governed by an HOA. The fee is charged by the HOA to provide a document that discloses any outstanding HOA-related issues with the property. The Estoppel document is part of the required dilligence of title companies in closing a sale.