Memorandum Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in petitioner's income tax for the fiscal year ended September 30, 1964, in the amount of $876.34. The issue presented is whether two sums totaling $3,650 received by petitioner during the tax year in controversy constituted advance rentals to be included in gross income, as determined by the respondent, or nontaxable security deposits, as contended by the petitioner. We agree with...
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