Memorandum Findings of Fact and Opinion
SCOTT, Judge:
The respondent determined deficiencies in petitioner's income tax for the years 1951 and 1952 in the amounts of $105,756.01 and $11,933.22, respectively. The only issue for decision is the correctness of respondent's determination that of the amounts claimed by petitioner as deductions for rental expenses, $117,325.10 for the year 1951 and $148,576.50 for the year 1952, did not represent ordinary and...
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