Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner has determined a deficiency in the income tax liability of the petitioner for the year 1944 in the amount of $2,086.72.
The issue in this proceeding is whether or not the payment by petitioner of attorney's fees and incidental expenses in connection with litigation involving a trust estate of which his wife was the ultimate beneficiary is deductible under section 23 (a) (1) ...
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