Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax against the petitioners of $3,583.59 for 1947. The principal basis of this deficiency is the respondent's disallowance of $12,647.84 in legal fees and traveling and living expenses. The petitioner had claimed this amount as ordinary and necessary expenses paid for the management, conservation, or maintenance of property held for the production of...
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