BRUCE, Judge:
This proceeding involves deficiencies in income tax for the calendar years 1954 and 1955 in the respective amounts of $11,163.14 and $11,879.13. The only issue is whether the sums of $16,500 and $18,000 paid by Briggs Manufacturing Company to the Detroit Trust Company, trustee, in 1954 and 1955, respectively, as compensation to the principal petitioner under an amended employment contract constituted taxable income in the years paid.
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