Memorandum Opinion
KERN, Judge:
Respondent determined a deficiency of $115,043.94 in petitioner's Federal income tax for the fiscal year ended September 30, 1959. In his notice of deficiency respondent also disallowed a claim for refund filed by petitioner for the fiscal year ended September 30, 1959, in the amount of $44,195.91. In its petition to this Court petitioner alleged that respondent erred in determining the deficiency and in disallowing the claim...
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