Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined deficiencies in income tax for the years 1947, 1948, and 1949, in the amounts of $18,042.56, $22,593.41, and $16,422.21, respectively.
The only issue for decision is whether the amounts paid by petitioner as rent under a percentage lease which was executed in 1940 represented true rent, deductible in full as ordinary and necessary business expense, in each of the taxable...
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