OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $15,731.20 in the petitioner's income tax for its fiscal year ended September 30, 1952. The petitioner contests the Commissioner's disallowance of $22,520 claimed as a deduction in the taxable year in question as a contribution to a profit-sharing plan and trust.
The facts have been stipulated.
The petitioner is a New York corporation doing business in Rochester,...
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