DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax for the taxable year 1962 in the amount of $19,441.53.
The sole issue remaining for decision is whether petitioners are entitled to a deduction of $30,000, the par value of stock in a corporation owned by petitioner transferred by petitioner to two individuals as commissions for sale of unissued stock of the corporation, either as an "ordinary and necessary" business expense...
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