Respondent has determined a deficiency in the amount of $24,279.47 in petitioner's income and victory tax for the year 1943. The principal issue is whether a contribution to a tax exempt charitable institution made subject to the donee's compliance with certain conditions, and paid by a check that was delivered on December 31, 1942, to a payee who was not the donee, is deductible in that year or in the year 1943 when the donee agreed to comply with the conditions of the gift...
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