Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $1,451.42 in the petitioner's income tax for 1949. The only issue for decision is whether fees to an attorney and to an accountant in defense of a lawsuit are deductible as ordinary and necessary expenses under section 23 (a) (2). The facts have been stipulated and are found as stipulated.
The petitioner filed his individual return for 1949 with the collector of internal...
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