OPINION.
OPPER, Judge:
This proceeding was brought for a redetermination of a deficiency of $4,238.71 in the petitioner's income tax for the year 1939.
Certain items are conceded by petitioner. The litigated issue is whether a fee paid attorneys is deductible under section 23 (a) of the Internal Revenue Code. An alternative contention by petitioner is that the amount involved is deductible as a loss under section 23 (e).
The facts...
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