Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner attacks respondent's determination of a deficiency of $97,049.79 in income and victory tax for 1943, and a deficiency of $62,878.87 in income tax for 1944. Computation of the deficiency for 1943 involves also the income for 1942, under the Current Tax Payment Act of 1943. The deficiencies result from attributing to petitioner 100 per cent of the net income of an enterprise instead of 50 per...
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