Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent determined a deficiency in Federal income tax of petitioner for the year 1951 in the sum of $11,319.35, resulting from his disallowance of a deduction on account of attorneys' fees in the amount of $16,300 "for the reason that the fees are not an ordinary and necessary expense within the provisions of Section 23(a) of the Internal Revenue Code of 1939."
The parties have filed herein...
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