ATKINS, Judge:
A deficiency in the amount of $2,686.74 in income tax determined by the respondent for the calendar year 1950 results entirely from the disallowance of a deduction claimed on the return in the amount of $10,278.57 as representing a legal fee paid. The respondent held that since the amount was not paid by the petitioner as a legal fee, but rather was paid by him to his controlled corporation
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