GARDNER, Chief Judge.
This matter is before us on a petition of the taxpayer to review an adverse decision of the Tax Court of the United States determining a deficiency in his income tax liability for the year 1946 in the sum of 1495.09. The facts were stipulated and found by the court as stipulated so are not here in dispute.
The controversy arises over the claim of the taxpayer that he is entitled to a deduction from his 1946 income of a $5,000 payment...
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