Memorandum Opinion
TANNENWALD, Judge:
Respondent has determined a deficiency in petitioners' income taxes for the fiscal year ended January 31, 1961 in the amount of $1,096.45. The questions presented are:
(1) The deductibility as ordinary and necessary expenses under section 212 of the 1954 Internal Revenue Code of expenses incurred by petitioners in connection with the retention of certain funds that petitioner William Scheefer received as beneficiary...
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