Memorandum Findings of Fact and Opinion
OPPER, Judge:
By this proceeding petitioner challenges respondent's determination of deficiencies in income tax of $1,199.02, in declared value excess-profits tax of $10,735.06, and in excess-profits tax of $58,421.08 for the year 1944.
The primary litigated issue is whether petitioner is entitled to a deduction as a business expense of $89,767.73 said to represent...
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