Memorandum Findings of Fact and Opinion
WITHEY, Judge:
In Docket No. 79877 deficiencies in income tax have been determined by respondent for the taxable years 1953, 1954, and 1955 in the respective amounts of $100,389.77, $889.82, and $5,095.53. In Docket No. 80893 deficiencies in income tax have been determined for the taxable years 1953 and 1954 in the respective amounts of $233,816.53 and $30,541.84.
The issues presented are:
(1) Is the...
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