The Commissioner determined income tax deficiencies of $2,192.93 for 1943 and $6,836.49 for 1944 against the petitioner. The only issue for decision is whether all or some part of the amounts paid in each year as attorney's fees is deductible as an ordinary and necessary expense and is not a capital expenditure.
FINDINGS OF FACT.
The petitioner filed its tax returns for 1943 and 1944 with the collector of internal revenue for the district of Oklahoma.
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