Respondent determined a deficiency in income tax of petitioner for the year 1952, the only year before us, of $237,269.31. Respondent also determined overassessments for 1951 of $9,341.71 and for 1953 of $35,075.98. By an amendment to answer respondent asks for an increased deficiency of $370,327.62. The reasons stated by respondent as the basis for the above-stated amount of increased deficiency are alleged in his amendment to answer as follows:
(a) That in computing...
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