Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioner's income tax for the fiscal years ending April 30, 1961, and April 30, 1962, in the respective amounts of $14,560 and $25,306.66. The principal question presented for decision is whether a prior adjudication by the United States Court of Claims, to which certiorari was denied by the Supreme Court (363 U.S. 819 (1960)), involving petitioner's tax liability...
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