HASTIE, Circuit Judge.
This is a petition for review of a decision of the Tax Court upholding the Commissioner's finding of a deficiency in petitioner's 1953 income tax return. The Tax Court held that in the circumstances of this case statutory penalties paid to the City of Pittsburgh and the School District of Pittsburgh for late payment of certain mercantile taxes are not deductible from gross incomes as "ordinary and necessary" business expenses within the meaning...
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