Memorandum Findings of Fact and Opinion
KERN, Judge:
These two proceedings were consolidated for hearing and opinion. In Docket No. 15475 the respondent determined a deficiency in income tax for the year 1944 in the sum of $58,441.99; in Docket No. 15476 he determined a deficiency in income tax for the year 1944 in the sum of $61,841. In each of these proceedings practically the entire amount of the deficiency determined resulted in the respondent's disallowance...
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