This proceeding involves a deficiency of $10,074.67 in income taxes for 1946. The sole issue raised by the petition is whether an attorney fee paid in connection with a transaction involving the sale of stock is deductible as an ordinary and necessary expense. Petitioner alleges that he is entitled to a refund in an amount of $3,837.70. Respondent by affirmative pleading, raising issues in the alternative, asks that the deficiency be increased to $76,576.25. The stipulation...
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