OPINION.
VAN FOSSAN, Judge:
Respondent determined a deficiency of $404.38 in petitioner's income tax for the year 1949. The deficiency was, in part, consequent on respondent's holding that the sum of $746.50 expended by petitioner in November and December 1949 for the payment of 1949-1950 real property ad valorem taxes on two parcels of real estate acquired by petitioner in April 1949, should be capitalized as a part of the cost of such property and...
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