Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies of $13,235 and $4,908 in petitioner's Federal income taxes for 1975 and 1976, respectively. Because of concessions by both parties, the only issue presented is whether petitioner, a corporation, is entitled to deduct legal fees it paid in 1975 for the defense of its president, the corporation's sole shareholder, on charges of criminal tax fraud.
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