MULRONEY, Judge:
The respondent determined a deficiency in petitioner's 1956 corporate income tax of $87,778.30.
Petitioner incurred a liability of $185,427 in 1956 under an agreement with the Pennsylvania Department of Highways. The issue for decision is whether said liability constituted an ordinary and necessary business expense deductible under section 162, I.R.C. 1954,
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