HARTIGAN, Circuit Judge.
This case arises on taxpayer's petition for review of a decision of the Tax Court of the United States entered May 15, 1951. It involves a deficiency of income tax for the year 1945 in the amount of $1,053.90 and is brought pursuant to Section 1141(a) of the Internal Revenue Code as amended by Section 36 of the Act of June 25, 1948, 26 U.S.C.A. § 1141(a).
The petitioner's statement of points is as follows:
"(1) The Court...
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