WITHEY, Judge:
The respondent has determined a deficiency of $457,650.62 in the petitioner's income tax for 1951. The primary issue presented is the correctness of the respondent's action in determining that for the taxable year in question the petitioner was not entitled to any deduction with respect to insurance on the lives of its retired employees, other than the amount of premiums accrued during the year on such insurance, and in accordingly disallowing...
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