Memorandum Opinion
ARNOLD, Judge:
Respondent determined a deficiency in petitioner's income tax for 1944 and 1945 in the amount of $487.57. Petitioner concedes a deficiency of $30.52 for 1944, but contests a deficiency of $457.05 for 1945, resulting from the disallowance of $1,686.30 deducted on its 1945 return. This amount was paid in settlement of the contingent liability of petitioner or its predecessors to a mutual insurance company under policies of...
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