Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding involves deficiencies in income taxes as follows:
1938 ............... $14,549.58 1939 ............... 14,651.16 1940 ............... 22,402.82
The petitioner claims overpayment in each of the respective years as follows:
1938 ............... $11,792.47 1939 ............... 20,436.24 1940 ............... 31,965.40...
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