WHALEY, Judge.
The facts in this case have been stipulated. It appears from the agreed facts that the plaintiff made no claim for deduction of attorneys' fees in his income tax return for the year, 1932, but in March, 1935, he filed a claim for refund claiming this deduction. The Commissioner refused the deduction and rejected the claim.
The sole question is whether plaintiff is entitled to have this deduction under Section 23(a) of the Revenue Act of 1932...
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