This proceeding involves a deficiency of $539 in income tax and $134.75 in delinquency "penalties" for the calendar year 1948. The issues to be decided are whether amounts paid by petitioner on behalf of two corporations of which he was a stockholder are allowable as his business deductions, and whether the delinquency "penalty" under section 291 (a) of the Internal Revenue Code of 1939 is applicable.
FINDINGS OF FACT.
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