Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1951 in the amount of $26,615.01. The issue for decision is whether petitioner's contribution in 1951 to "The Branham Company Pension Trust" is deductible under section 23(p) of the Internal Revenue Code of 1939.
Findings of Fact
Some of the facts have been stipulated and are hereby found as stipulated.
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