Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year ended February 29, 1960, in the amount of $13,865.98. The issues presented are whether the respondent erred in allocating to the petitioner, pursuant to section 482 of the Internal Revenue Code of 1954, taxable income reported by the petitioner's wholly owned subsidiary, and whether the respondent erred in disallowing as a deduction...
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