The Commissioner determined deficiencies in declared value excess profits tax and excess profits tax for the fiscal year ended April 30, 1946, in the amounts of $1,890.64 and $97,868. The issues are: (1) Was petitioner entitled to deduct as a business expense the sum of $7,942.04 expended during the taxable year by the Midwest Research Institute out of the total of $20,000 paid by petitioner to the institute to carry on certain research and development work for petitioner...
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