The respondent determined income tax deficiencies for the years 1945, 1947, and 1948 in the amounts of $56,559.62, $51,910.67, and $53,812.36, respectively. At the hearing it was orally stipulated that there is no deficiency in income tax for the taxable year 1948. Other adjustments relating to the taxable years 1945 and 1947 are set forth in the stipulations of facts.
The sole issue for our determination is whether certain payments made by a corporation in partial...
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