OPINION.
TIETJENS, Judge:
The Commissioner determined a deficiency in petitioner's income tax for the year 1953 in the amount of $53,316.45. The only issue for decision is whether petitioner is entitled to a deduction in the year 1953 in the amount of $8,271.07 paid to the City of Pittsburgh and the School District of Pittsburgh as a so-called penalty for nonpayment of mercantile license tax when due.
All of the facts are stipulated. They...
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