DAWSON, Judge:
Respondent determined a deficiency of $88,146.71 in the income tax of petitioner for the year 1961.
In his reply brief respondent has conceded that accrued bond interest of $52,751.31 need not be included in the gross income of either petitioner or Gulf Stream Investment Co., Ltd., his foreign personal holding company. Thus the two issues remaining for decision are: (1) Whether...
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