Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The Commissioner determined a deficiency in petitioner's income tax liability for the year 1943 in the amount of $28,609.65. Because of the operation of the Current Tax Payment Act of 1943, the income tax return for 1942 is also involved. The respondent increased the petitioner's gross income for 1942 by $26,577.45 and for 1943 by $25,513.26.
The petition raises two issues on which the parties...
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