Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $26,254.12 in the income tax of the petitioners for 1960. The only issue for determination is the correctness of the respondent's determination that $68,100.62 of a deduction of $74,410.62 taken by petitioners for 1960 for legal and professional fees and expenses did not constitute an allowable deduction...
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