OPINION.
MULRONEY, Judge:
Respondent determined a deficiency in income tax for the taxable year 1950 in the amount of $1,970.67. All of the facts were stipulated and it was also stipulated:
The only issue before the Court is whether petitioner is entitled to deduct as investment expenses those portions of real estate taxes and expenses and depreciation on its home office property which were allocated by petitioner to its investment operations...
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