Memorandum Findings of Fact and Opinion
This case involves a deficiency in corporate income tax for the year 1947 in the sum of $8,606.52. The two issues presented for decision are: (1) was the sum of $22,500, paid by petitioner in 1947 under a lease containing an option to buy, a rental payment or did it represent a part of the purchase price of the property covered by the lease; and (2) what was the useful life of a power plant purchased by petitioner in 1947...
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