OPINION.
OPPER, Judge:
Petitioner challenges respondent's determination of a deficiency in income and victory taxes of $2,194.93 for the calendar year 1943.
The problem involves the interrelated effect of section 107 (a) of the Internal Revenue Code and the so-called "forgiveness" features (section 6) of the Current Tax Payment Act of 1943 upon income received in lump sums in 1943 for services rendered over a period of years including 1942...
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