DAVID T. LEWIS, Circuit Judge.
This is a petition for review of a decision of the Tax Court sustaining the Commissioner's determination of income tax deficiencies and penalties for the taxable years 1953 and 1954. Venue for review having been stipulated by the parties, jurisdiction is conferred upon this court by section 7482 of the Internal Revenue Code of 1954. The decision of the Tax Court is premised entirely upon the presumptive correctness of the Commissioner...
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