Memorandum Opinion
MELLOTT, Judge:
Petitioner, a resident of Oregon, filing his income tax returns on a cash basis with the collector of internal revenue for that district, assails a deficiency in income tax for the calendar year 1940 in the amount of $6,880.18 and claims he has made an overpayment in tax. Respondent denies this although he concedes that the deficiency determined by him is excessive.
[The Facts]
There is no dispute...
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