BROWNING, Circuit Judge:
Three Transamerica subsidiaries filed separate income tax returns for 1953. The returns were prepared on a cash basis, and therefore omitted certain income which accrued to the taxpayers in 1953 but was not actually received until 1954. The income of the three subsidiaries for 1954 was reported in a consolidated return filed on behalf of Transamerica and approximately seventy of its subsidiaries. The consolidated return was prepared on an...
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