Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in income tax in the amount of $7,789.78 against petitioner for the fiscal year ended June 30, 1945. The only question is whether petitioner is entitled to a deduction in the amount of $15,459.25, representing part of a payment made by him to the United States in connection with a controversy involving petitioner's sales made at allegedly over-ceiling prices.
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