Memorandum Opinion
HILL, Judge:
The Commissioner determined a deficiency in income tax of $99,061.56, together with a penalty of $24,765.39, for the taxable year 1938. The principal issue is whether all of the proceeds of a damage suit should have been included in petitioner's gross income or whether only one-fourth of the proceeds were properly includible therein. The second issue is whether or not certain attorney's fees were deductible. Respondent disallowed...
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