Memorandum Findings of Fact and Opinion
This case involves deficiencies in income tax for 1941 in the amount of $6,834.09, and in excess profits taxes for 1940 and 1941 totaling $29,692.92.
Two separate questions are presented for decision. The first is whether the sum of $22,504.12 paid by petitioner in 1941 to the trustee of a pension trust is deductible as a business expense under section 23 (a) (1) of the Internal Revenue Code or as an amount transferred...
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