Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $10,274.25 in the income tax of petitioners for 1973. At issue is the taxpayer's right to deduct certain payments made by his wholly-owned corporation in respect of liabilities and expenses incurred by his predecessor sole proprietorship. Concessions by the parties have eliminated other issues.
Findings of Fact
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