Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $4,554.48 and $1,029.04 in the petitioner's income and excess profits taxes respectively for the year 1939.
The single issue is whether or not the petitioner is entitled to the deduction of a $25,000 payment made to an employees' pension trust.
In the alternative, the petitioner claims the deduction as an ordinary and necessary business expense.
Findings of...
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