Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency in the income tax of the petitioners for 1947 in the amount of $3,678.33. The issue presented is the correctness of the respondent's action in determining that compensation received by the petitioners should be reduced by a legal fee paid in 1947 to collect the compensation before allocation of the compensation is made to prior years under section 107 of the...
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