Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax for 1956 and 1959 of $4,585.79 and $2,246.53, respectively. The facts are fully stipulated and are hereby found as stipulated.
The controlling question is whether expenses required to complete the petitioner's subcontract for road construction work which were paid by petitioner's surety under the provisions of a subcontractor's performance bond for the completion of the contract...