OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the taxable year ended December 31, 1953, in the amount of $3,002.74.
The only error assigned is "The Commissioner erred in disallowing a deduction of $8,890.50 as `fees' paid by petitioner Bert B. Rand to S. A. Carraway."
The facts were all stipulated and are incorporated herein by this reference.
Petitioners are husband and wife and during the...
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