Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined a deficiency in the corporate income tax of petitioner for the fiscal year ending April 30, 1968, in the amount of $297,552.04.
The following questions are presented to the Court for our determination:
(1) Whether respondent properly allocated income in the amount of $193,045.37 pursuant to his authority under section 482
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