Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding, after concessions made at trial, involves a deficiency in income tax in the amount of $63,676.05 for the taxable year ended October 31, 1942, and a deficiency of $11,311.90 in income and victory taxes for the fiscal year ended October 31, 1944. The principal issue is whether the income of the Wholesale Supply Co., for the years 1942 and 1944, is taxable to petitioner. An overpayment...
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