OPINION
TIETJENS, Judge:
The Commissioner determined deficiencies in petitioner's income tax of $433.33 and $2,500, respectively, for 1963 and 1964.
We must decide what portion, if any, of a $25,000 payment petitioner made to the Bingham Co., pursuant to an agreement between them, was paid for property which is subject to depreciation.
The facts have been fully stipulated. The stipulation and the exhibits attached thereto are incorporated...
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