The respondent has determined a deficiency of $58,594.96 in the petitioner's excess profits tax for 1945. The issues presented are (1) whether certain payments totaling $66,655.06 received by petitioner in 1945 from the Reconstruction Finance Corporation constituted taxable income for 1945, (2) if such payments constituted taxable income for 1945, then whether the amount thereof was properly deductible for that year as a liability to make repayment thereof to the Reconstruction...
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