Memorandum Opinion
TRAIN, Judge:
Respondent determined deficiencies in petitioner's income taxes for the taxable years ended December 31, 1952, and December 31, 1953, as follows:
Year Deficiency 1952 ............. $57,111.13 1953 ............. 18,097.38
The deficiency for the taxable year 1953 depends upon a determination of a deficiency for 1952. The issues to be decided relate to the treatment to...
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