Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined deficiencies in the income taxes of the petitioners in the amounts of $309.30 for the year 1950, and $309.08 for the year 1951.
The issue for decision is whether certain club dues paid by one of the principal executive officers of a trust company are deductible by him as ordinary and necessary business expenses.
Findings of Fact
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