The respondent has determined a deficiency in income tax for the year 1945 in the amount of $17,593.29. The petitioner agrees that several determinations of the respondent are correct. He contests only the determination that attorneys' fees in the amount of $16,966.66 are not deductible under section 23 (a) (2) of the Internal Revenue Code, or any other provisions of section 23. The respondent made the following determination:
The amount * * * deducted in your return...
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