STERRETT, Judge:
Respondent asserted a deficiency of $17,578 in petitioner's income tax for the calendar year 1969. The only aspect of the deficiency that remains in dispute concerns the deductibility of fiduciary commissions, amounting to $53,894.67, which petitioner paid to Bankers Trust Co. on June 16, 1969, upon termination of a trust account. What portion of that commission expense is allocable to tax-exempt income and therefore not deductible is the question...
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