Gerald L. and Erma L. Dunnegan - Page 15




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          such services were actually received.  In addition, the services            
          rendered by the charitable organization were ordinary and                   
          necessary to the operation of J&G Enterprise.  We conclude that             
          the payments are deductible as a business expense under section             
          162.                                                                        
               To reflect the foregoing and the concessions of the parties,           
                                                  Decision will be entered            
                                             under Rule 155.                          


































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