FORRESTER, Judge:
Respondent has determined deficiencies in the 1951 and 1952 income tax of petitioners in the respective amounts of $531 and $624.03. The issues are as follows:
1. Did respondent err in disallowing claimed depreciation deductions in respect of an automobile?
2. Did respondent err in determining that payments to Walter I. Geer by the State of Georgia as "contingent expense allowance" were includible in gross income?
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