Memorandum Findings of Fact and Opinion
HILL, Judge:
These proceedings have been consolidated by stipulation of the parties. Docket No. 1935 involves income tax deficiency for the year 1940 in the sum of $113,911.99, and Docket No. 2762 involves gift tax deficiencies for the years 1940 and 1941 in the amounts of $18,214.35 and $175,535.25, respectively. In each case petitioner avers that an overpayment has been made. In Docket No. 1935 certain adjustments...
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