Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the fiscal year ended September 30, 1952, in the amount of $74,066.01. The following two fiscal years are involved solely because of net operating loss carrybacks.
The sole issue for decision is the treatment of $272,913.26 which petitioner deducted as "Participation Payable in Iron and Pipe Joints." The deductibility of this item...
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