Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined deficiencies in the income tax of petitioner for the taxable years 1956 and 1957 in the respective amounts of $967.50 and $1,027.41. The sole issue presented by the pleadings is whether respondent has erred in disallowing as an amortization deduction in each year one-fifth the cost to petitioner of an expiration list acquired from the estate of a casualty insurance agent...
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