SIMONS, Circuit Judge.
In 1928 and 1930 the petitioner paid out large sums for attorney fees and expenses in connection with suits to recover income taxes paid for the year 1919. The respondent disallowed deductions for such fees and expenses on the ground that they did not constitute "ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business" within the meaning of § 23 (a) of the Revenue Act of 1928, 26 U.S...
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