The respondent has determined a deficiency of $13,771.62 in petitioner's income tax for the taxable year ended December 31, 1946. The entire deficiency results from the respondent's determination that the sum of $33,320 paid to the petitioner upon the execution of a lease in 1946 was paid in prepayment of rent rather than as a security deposit, and was taxable income in that year. An additional sum of $10,000 designated in the lease as security and paid in later years is...
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