Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $10,245.28 in income tax of the petitioner for its fiscal year ended January 31, 1957. The only issue for decision is whether the Commissioner erred in disallowing a deduction of $15,278.22 for legal fees which he explained was "properly chargeable to capital."
The parties have presented the facts by a few admissions and a stipulation which are adopted as the findings...
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