The Commissioner determined deficiencies of $20,101.55 and $5,727.30 in the petitioner's income tax for its fiscal years ending March 31, 1950 and 1951. The issues are whether payments to the petitioner in each year were advanced rents or amounts realized from the sale of "goodwill" of gas stations at a price not greater than the petitioner's cost; whether the compensation paid to its officers in the taxable fiscal year 1951 was reasonable in amount; and whether the petitioner...
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