PHILLIPS, Circuit Judge.
Peter W. DeFelice and Norma G. DeFelice, husband and wife, have filed a petition to review a decision of the Tax Court sustaining a tax deficiency in their income tax for the year 1958, determined and assessed by the Commissioner, and sustaining the denial by the Commissioner of an income tax deduction claimed by them in their return for the year 1959.
Prior to 1958, Peter was the sole owner and the operator of an advertising agency...
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