This proceeding involves a deficiency in income tax in the amount of $201.16 asserted by respondent for the fiscal year ended October 31, 1947, and petitioner's claim of an overpayment in the amount of $168.02. Petitioner has conceded that the additions to income as set forth in the notice of deficiency are correct. It contends, however, that respondent erred in determining the deficiency, by failing to exclude from reported income 85 per cent of an item of $859.50, which...
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