Memorandum Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioner's decedent for the taxable year 1961 in the amount of $1,464.24. The sole issue is whether respondent has properly disallowed as a deduction an attorney fee paid by decedent during that year.
All of the facts have been stipulated and we incorporate such facts together with the exhibits attached to the stipulation herein by reference.
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