The Commissioner determined a deficiency in income tax for the year 1950 in the amount of $6,492.02.
The only question for decision is whether or not certain attorney fees paid by petitioner Hymie Schwartz in 1950 in connection with his income tax liabilities for prior years were deductible under section 23 (a) (1) or section 23 (a) (2), Internal Revenue Code.
FINDINGS OF FACT.
Petitioners are husband and wife residing in Dallas, Texas. They filed...
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