WITHEY, Judge:
The respondent determined a deficiency of $1,276.23 in the income tax of petitioner for 1949.
The sole issue presented is the correctness of the respondent's action in determining that petitioner is not entitled to a deduction for certain Delaware ad valorem taxes accrued and paid in 1949 on real estate acquired on May 2, 1949, and situated in Wilmington, Delaware.
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