OPINION. Arundell, Judge: The petitioner claimed a deduction of $24,938.34 in 1942 and $30,406.74 in 1943 as rentals paid his wife for the use of her property in a manufacturing concern owned and operated by him. The respondent has determined that these sums are excessive to the ■extent that they exceed $2,400 for 1942 and $1,000 for 1943, and that this excess was a gift.…
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