Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined a deficiency of $3,169.24 in the petitioners' income tax for 1949. The issues presented by the pleadings are the correctness of the respondent's action (1) in determining that consulting fees in the amount of $12,000 constituted income to petitioner Lawrence S. Vadner, (2) in disallowing as a deduction for entertainment expense an amount of $40 for amusement and liquor taxes...
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