The Commissioner determined a deficiency in petitioner's income tax of $461,454.38 for the year 1963. Petitioner disputes so much of that deficiency as is based upon the Commissioner's disallowance of a deduction in the amount of $882,636.86, which petitioner claimed as a "Federal Insurance Premium" expense in that year. Petitioner paid this amount to the Federal Savings and Loan Insurance Corporation in 1963, as well as its regular annual insurance premium for that year...
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