Memorandum Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioner's income tax for the tax years 1966 and 1967 in the amounts of $13,372.18 and $10,449.96, respectively.
The only issue presented is whether certain legal expenses incurred by petitioner in defense of a suit for malicious prosecution are deductible under section 212(2) of the Code.
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