Memorandum Findings of Fact and Opinion
LEECH, Judge:
These cases were consolidated. In Docket No. 109427, the petitioner seeks a redetermination of income tax deficiencies for the calendar year 1937 in the sum of $91,756.09 and $438,251.33 for 1938 and claims overpayment for the calendar year 1938 of $127,192.46. In Docket No. 109416, petitioner seeks a redetermination of an income tax deficiency for the calendar year 1938 in the amount of $37.15.
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