Memorandum Findings of Fact and Opinion
HOYT, Judge:
These proceedings have been consolidated.
Respondent determined an income tax deficiency against petitioner Western New York Water Company (Docket No. 89282) for the calendar year 1953, in the amount of $1,688,878.90, all of which is in controversy. Petitioner claims an overpayment of $49,030.87 in income tax for the taxable year 1953.
Respondent determined that petitioner Utilities &...
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