PIERCE, Judge:
Respondent determined deficiencies in the income taxes of the petitioners for the calendar years 1957 and 1958 in the amounts of $5,472.39 and $5,684.35, respectively.
The issues for decision are:
(1) Did the Commissioner err in determining that the amounts of $11,779.40 and $14,146.25, which were paid in the respective taxable years by Hum International (a partnership of which petitioner Egbert Miles was a member) to two Bermuda...
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