This proceeding involves a deficiency in income tax for the year 1952 in this amount of $28,235.84, determined by respondent under the provisions of the Internal Revenue Code of 1939, and a deficiency in income tax for the year 1954 in the amount of $40,092.22, determined by the respondent under the provisions of the Internal Revenue Code of 1954.
The issue to be decided is whether certain sums paid by petitioner Arthur B. Koontz in 1952 and 1954 were deductible as...
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