The respondent has determined a deficiency in the petitioner's income tax liability for the year 1946 in the amount of $61,757.33. The petitioner concedes the correctness of certain adjustments made by the respondent to her income for 1946. This will be given effect in the computation under Rule 50.
On her return for the taxable year the petitioner deducted the sum of $90,338.04, consisting of attorneys' fees and other expenses of litigation. The respondent allowed...
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