Memorandum Findings of Fact and Opinion
This proceeding involves deficiencies in income and excess profits taxes for the calendar year 1945 in the respective amounts of $409.39 and $6,808. The sole issue is whether an expenditure of $6,515, representing the cost of repointing a brick building, is a repair item, deductible as an ordinary and necessary business expense of the taxable year, or, is a capital expenditure, recoverable through depreciation allowances....
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