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agreement allowed amount annuity apply basis Burger Chef business expenses capital asset capital gains capital loss cash charitable Circuit claim Commissioner compensation Congress contract corporation cost Court held Court of Appeals debt deduction deferred depreciation determined disallowed earned economic employee example excluded exemption fair market value funds gift gift tax gross income income tax incurred interest Internal Revenue Code Internal Revenue Service investment issue itemized deductions lease limited loan married couples ment method of accounting mortgage nonrecourse nonrecourse debt obligation ordinary income paid partnership payments percent permitted petitioner petitioner's produce profit provides purchase realized receipt received result Rev.Rul Revenue Ruling Section standard deduction statute supra Supreme Court tax benefit Tax Court tax expenditure tax liability tax purposes tax rate taxable income taxation taxpayer tion trade or business transaction transfer treated treatment trust United Worthen