DAWSON, Judge:
Respondent determined income tax deficiencies against petitioner for the taxable years 1961 and 1962 in the amounts of $327,940.14 and $692,528.21, respectively.
Petitioner has apparently abandoned the argument made at trial that respondent has the burden of proof with respect to allegations contained in the amended answer. The parties have resolved the issues pertaining to the year 1962 and have agreed upon the deficiency, subject to...
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