Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined deficiencies of $58,845.87 and $86,776.45 in the income taxes of the Maryland National Bank for the calendar years 1967 and 1968, respectively.
After concessions with respect to other issues, only one question remains for our decision: whether $156,375, or any portion thereof, of the purchase price paid by petitioner in 1967 to acquire the business of Charg-It of Baltimore...
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