Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency in petitioner's income tax for taxable year 1964 in the amount of $198,667.75. Some of the issues have been settled by the parties. The issues remaining for decision are:
(1) Whether petition is entitled to deductions for certain expenditures made in 1964 as ordinary and necessary business expenses; and, alternatively, if found to be ordinary and necessary business...
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