The respondent has determined deficiencies in the petitioner's income tax liability for the taxable years ended September 30, 1945, 1946, and 1947 in the amounts of $645.52, $1,571.20 and $39,011.89, respectively, and a 25 per cent delinquency penalty amounting to $161.38 for the taxable year ended September 30, 1945. Some of the issues raised in the pleadings have been settled by the parties. Two issues remain for decision: (1) whether the sum of $120,000 paid to petitioner...
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