Memorandum Opinion
GOFFE, Judge:
The Commissioner determined a deficiency of $19,005.72 in petitioner's Federal income tax for the taxable year ended September 30, 1971. The sole issue for decision is whether the timely issuance and delivery of petitioner's promissory note to the trustees of the trust for its pension plan constitutes "payment" for purposes of section 404(a) of the Internal Revenue Code of 1954,
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