KENNEDY, Circuit Judge:
The principal issue on this appeal is the deductibility by a cash basis taxpayer of management fees it voluntarily paid in advance for services to be rendered beyond the taxable period. Appellant is transferee of the assets of Branjon, Inc., which was the transferee of the assets of N & V Realty Corporation ("N & V" or "N & V Realty"). Appellant is therefore liable for the deficiency in income taxes levied by the Commissioner against...
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