HEALY, Circuit Judge.
This is an appeal by the Commissioner from a decision of the Tax Court allowing, as reasonable business expenses, deductions for payments made by respondent taxpayer to three of its stockholders for the years 1948 and 1949. The payments were made pursuant to a written contract entered into in 1944 which extended the term of a similar contract that had been made in 1931. These payment contracts arose under circumstances now to be stated.
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