Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined deficiencies in income tax of $15,707.51 for 1948 and $4,477.50 for 1949. The only issue for 1948 is whether $34,359.39 was deductible as interest and the only issue for 1949 is whether $7,500, an attorney's fee, was deductible as a non-business ordinary and necessary expense for the production of income within section 23 (a) (2). The facts have been presented solely by a stipulation.
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