Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in income tax for the calendar year 1939 against petitioner in the amount of $6,763.92. There are only two issues. The first issue is whether income from a trust of which petitioner was grantor is taxable to petitioner. The second issue concerns the deductibility of certain accountant and attorney fees paid by petitioner in recovering overpaid income taxes.
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