SIMPSON, Judge:
The respondent determined deficiencies in the petitioner's income taxes of $212,842.90 for the taxable year 1962 and $36,547.03 for the taxable year 1963. Some of the issues have been settled, and the only question remaining for decision is whether the respondent erred in revaluing the petitioner's opening and closing inventories to include therein an allocable portion of indirect manufacturing expenses.
FINDINGS OF FACT
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