Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves the redetermination of deficiencies in income taxes for 1937 and 1938 in the respective amounts of $5,797.96 and $2,372.81. They were determined prior to the enactment on October 21, 1942, of section 121 of the Revenue Act of 1942, amending section 23 (a) of the Internal Revenue Code by a new provision, reading as follows:
(a) EXPENSES. —
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