This proceeding involves the redetermination of deficiencies in income taxes for the calendar years 1936, 1937, 1938, and 1939 in the respective amounts of $290,028.13, $286,319.77, $246,698.07. and $253,083.49. The issues raised by the petition are whether any part of the income of petitioner is deductible under the provisions of section 162 (a) of the Revenue Acts of 1936 and 1938 and the Internal Revenue Code, and whether assessment of the deficiency for 1936 is barred...
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