SCOTT, Judge.
Respondent determined deficiencies in petitioner's income tax for the calendar years 1954 and 1955 in the amounts of $364,706.59 and $314,565.30, respectively. Petitioner claims an over-payment of tax in the amount of $28,521.78 for the year 1955.
The issues for decision are:
(1) Whether Investors Diversified Services, Inc., sustained losses aggregating $1,307,886.60 on sales of mortgage loans to two wholly owned subsidiaries during...
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