Memorandum Opinion
RICE, Judge:
The respondent determined a deficiency in income tax for the year 1944 in the amount of $209.19.
The question presented is whether petitioners are entitled to a deduction of $1,248.49 under section 23 (a) of the Internal Revenue Code or under section 23 (e) of the Code, which sum represented certain court costs arising out of litigation in the courts of Iowa. All of the facts were stipulated.
The stipulated...
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