The respondent has determined that there is a deficiency in income tax for the year 1943 in the amount of $1,150. The petitioner denies that there is a deficiency and claims a refund of tax for 1943 in the amount of $850.
The deficiency results from disallowance of a deduction of $5,000 which the petitioner claimed as an ordinary business expense under section 23 (a) of the Internal Revenue Code. The petitioner paid a fee of $5,000 to the New York Clearing House Association...
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