Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined deficiencies in petitioner's income tax liability as follows:
1948 ................... $4,300.58 1949 ................... $4,408.03
The issues presented for determination are whether respondent erred (1) in refusing to allow petitioner a deduction for legal, presidential and managerial expenses accrued during the calendar year 1948, payable...
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