Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $4,172.36 with respect to petitioner's income taxes for the taxable year ended June 30, 1960. Petitioner not only contests this deficiency but seeks an overpayment of income tax for its taxable year 1960 in the amount of $26,792.10. The total amount in controversy is thus $30,964.46.
The sole issue for decision is whether petitioner was entitled in its taxable...
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