WITHEY, Judge:
The respondent has determined a deficiency of $301,672.68 in the income tax of the petitioner for 1953. The only issues presented by the pleadings and not disposed of by stipulation of the parties are the correctness of the respondent's action in determining (1) that petitioner was not entitled under the provisions of section 23 (o) and (q) of the Internal Revenue Code of 1939 to deduct any amount as a contribution on account of petitioner's...
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