Respondent determined deficiencies in petitioner's income tax liability for the fiscal years ended November 30, 1937 and 1938, in the amounts of $109,023.16 and $69,504.08 respectively. A number of issues raised by the pleadings were settled by stipulations of the parties at the hearing and will be given effect upon final settlement under Rule 50. The two issues submitted for decision are (1) whether petitioner is entitled, under section 26 (c) (2) of the Revenue Act of 1936...
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