Memorandum Opinion
BLACK, Judge:
The Commissioner determined deficiencies in income tax of petitioner for the years 1958 and 1959 in the amounts of $22,916.90 and $79,173.37, respectively. In the notice of deficiency for 1958, the Commissioner made the following adjustments:
Taxable income shown on return ........ $58,849.65 Additional income and unallowable deduction: (a) Income attributed to Estate of Lester A. Russell...
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