Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined a deficiency in the petitioners' income tax of $47,450.19 for the taxable year 1960. The basic issue for decision is whether disbursements made by the petitioner, a practicing lawyer, to or on behalf of his clients in 1960, which were to be repaid upon the successful resolution of their legal claims, are deductible in 1960 as ordinary and necessary expenses of carrying on a...
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