OPINION.
HILL, Judge.
This proceeding involves an income tax deficiency for 1936 in the amount of $93,609.21. Petitioner, an individual, filed his 1936 tax return on the cash receipts and disbursements basis with the collector for the second New York district. The proceeding presents the following questions:
1. Did respondent err in disallowing the deduction of certain expenses allocable to income in respect of which no tax was paid or collectible...
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