Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax against Samuel Thorne for the year 1940 in the sum of $5,866.36. The single issue raised by the pleadings is whether, under section 23 (a) (2), I. R. C., the petitioner is entitled to deduct amounts expended as attorneys' and accountant's fees for services rendered in litigation and other matters involving his personal income tax.
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