Memorandum Opinion
PIERCE, Judge:
The respondent determined a deficiency in petitioner's income tax for the calendar year 1951 in the amount of $636.20, and an addition to tax under section 291(a) of the 1939 Code, in the amount of $159.05, for petitioner's delinquency in filing its income tax return for said year.
The only issues for decision are the amounts allowable to petitioner for the taxable year, as deductions for amortization of a hotel...
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