SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1963 and 1964 in the amounts of $10,906.50 and $12,683.27, respectively.
The issues for decision are:
(1) Whether the cost to one of petitioners of acquiring a management contract with a mutual assessment life insurance company is subject to depreciation or amortization and, if so, the period over which it may be amortized, and
(2) Whether respondent...
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