Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax against the petitioner in the amounts of $124.62 and $10,008.12 for the taxable years ended December 31, 1946 and 1947, respectively.
All of the issues raised by the pleadings have been resolved by agreement save one, i. e., whether the sum of $25,000 paid by the petitioner in 1947 to the Administrator, Office of Price Administration, in...
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