OPINION
TEHAN, Chief Judge.
The plaintiffs in this action, Leland H. Baum and Mildred Baum, seek a refund of income taxes paid for the year 1966 as a result of the alleged erroneous disallowance of a deduction for (1) $30,000 paid by Leland H. Baum to retire an obligation from Glenport Realty Corporation to Earl Milliken, Inc. which Mr. Baum, an officer of Glenport, and his wife had guaranteed, and, (2) $1,150.00 legal fees and expenses incurred by Mr. Baum...
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