The Commissioner has determined a deficiency in the income tax liability of the petitioner for the year 1946 in the amount of $5,834.78. The petitioner concedes that part of the deficiency was properly determined. However, he contests the disallowance of a deduction in the amount of $12,659 which he contends is deductible under either section 23 (a) (1) or section 23 (e) of the Internal Revenue Code.
The issue in this proceeding arises from the fact that the petitioner...
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