RUWE, Judge:
Respondent determined deficiencies in petitioner's 1985 and 1988 Federal income taxes in the respective amounts of $2,445,098 and $32,557,015.
After severance of certain issues for trial and concessions by the parties, the issues for decision are: (1) Whether certain deductions taken by petitioner in 1988 are prohibited by section 162(k);
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