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NOTES 693 Tax Lawyer, Vol. 56, No. 3 NOTE CRACKING WALNUTS WITH A SLEDGEHAMMER: THE UNCERTAINTY OF THE REALLOCATION DOCTRINE IN STEWART V. COMMISSIONER In Stewart v. Commissioner, the Tax Court held that the individual taxpayer could not deduct payments made by him as a sole proprietor to his whollyowwne corporation under a contract for management services, where he alone performed the services connected with those payments.1 The court concluded that the payments could not be considered...

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