Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioner's income tax for 1950 and 1951 in the amounts of $361,191.04 and $326,882.60, respectively. Respondent concedes that a deficiency determined for 1949 was erroneous. The issues are: (1) Did petitioner fail to include in income the amounts of $1,038,403.65 for the taxable year 1950 and $682,339.63 for the taxable year 1951; (2) has respondent changed his...
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