Memorandum Findings of Fact and Opinion
WITHEY, Judge:
These cases, duly consolidated, involve deficiencies in income taxes as follows: In Docket No. 32512 for the calendar year 1946 in the amount of $734.77 and in Docket No. 33880 for the calendar year 1946 in the amount of $7,737.58. The important issue raised in the petitions is whether an attorney fee paid proportionately by Raymond K. Dykema and Albert W. Russel, deceased, in connection with a stock...
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