The Commissioner has determined deficiencies in petitioners' income tax of $679.48 for 1946 and $446.49 for 1948. Some minor adjustments are not contested. The only adjustment in issue is one labeled in the deficiency notice "Annual payment to Mrs. R. J. Brown — purchase of practice $1,350.00." This adjustment is explained in the deficiency notice as follows:
(1) It has been determined that a payment of $1,350.00 made to Stella Brown, Executrix of the Estate...
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