The Commissioner determined deficiencies in income tax of $546 for 1958 and $271.83 for 1959 against the Howards and a deficiency of $3,282.69 for 1958 against the Fergusons. The only issue for decision is whether payments made to construct a new hospital were deductible as ordinary and necessary business expenses or, in the alternative, as charitable contributions.
FINDINGS OF FACT.
Howard and Ferguson are osteopathic physicians and surgeons who practiced...
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