Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent has determined a deficiency in the income tax of petitioner for the fiscal year ended April 30, 1960, in the amount of $55,017.51. The only issue raised by the pleadings is whether respondent has erred in disallowing the exclusion from petitioner's taxable income for its fiscal year ended April 30, 1958, of the amount of $90,000 received by it in settlement of a suit for damages and in the...
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