United States Tax Court April 9, 1973, Docket No. 3876-69 (Dubitzky v. Commissioner)

lead-opinion

Quealy, Judge:

Respondent determined deficiencies for the taxable years 1963 and 1964 in the amounts of $33,357.81 and $57,349.03, respectively.

Certain issues having been agreed to by the parties, the sole question remaining for determination is whether for the taxable year 1964 petitioners are entitled to a deduction under section 164(a) (1) 1 on account of the transfer of certain