Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies of $7,405.39 for 1941 and $12,960.62 for 1943. The issues presented are whether petitioner is entitled to apply section 107 of the Internal Revenue Code in computing his tax attributable to a fee received for certain legal services, and whether he is entitled to a deduction of $1,000 as a loss on a personal guaranty.
Findings of Fact
Petitioner is...
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