Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency in income tax for the fiscal year ended June 30, 1940, in the amount of $14,785.49. The deficiency is contested in part only. The only question is whether petitioner is entitled to a deduction of $65,000, which was paid in settlement of a threatened action in equity for a receivership and an accounting as a business expense or a loss under section 23 (a) or (f)...
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