Memorandum Findings of Fact and Opinion
The commissioner determined a deficiency of $2,427.65 in the income tax of the petitioner for 1946. The only issue for decision is whether the petitioner is entitled to deduct as an ordinary and necessary business expense $19,285.85 paid in 1946 allegedly to compromise threatened litigation.
[The Facts]
The petitioner filed its corporate income tax return for 1946 with the collector of internal revenue...
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