Memorandum Findings of Fact and Opinion
LEECH, Judge:
This case originally involved proposed deficiencies in income tax liability determined against the petitioner for the years 1940 and 1941 in the respective amounts of $4,372.24 and $19.25. It is stipulated that this Court may enter an order that there is no deficiency or overpayment as to 1941. The only issue as to the determination for 1940 is the deductibility, under section 162 (a), I. R. C. of income...
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