Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income tax determined against petitioner for the years 1951 and 1952 in the amounts of $4,192.77 and $5,674.50, respectively.
The issues to be decided are: (1) whether petitioner is entitled to deduct, as ordinary and necessary business expenses, attorney fees paid by it in the years 1951 and 1952 in the amounts of $5,000 and $7,500,
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