Memorandum Opinion
SMITH, J.:
This is a proceeding for the redetermination of deficiencies in income tax for the calendar years 1938 and 1939 in the respective amounts of $425.31 and $2,600.50. The question in issue is whether certain litigation expenses incurred and paid by the petitioner in 1938 and 1939 are deductible as "ordinary and necessary" expenses in computing petitioner's taxable income or constitute taxable expenditures which represent additional...
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