Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined a deficiency of $3,830.53 in petitioner's income tax for 1940. Petitioner, whose return was filed in the District of New York, assails so much as results from the disallowance of a deduction of a lawyer's fee of $3,755.51 for representing petitioner in a proceeding before the Board of Tax Appeals to contest a deficiency for 1935. The former proceeding, Charles E. Adams, 39 B. T. A....
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