The Commissioner determined a deficiency in income tax of $24,693.16 for 1948 and one of $37,621.49 for 1949. The issue for decision is whether one-half of the profits from a construction contract was properly a part of the net income of the petitioner although paid to Stevens Brothers Foundation, Inc., under an agreement pursuant to which the Foundation advanced to the petitioner money essential to the earning of the profits.
FINDINGS OF FACT.
The petitioner...
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