Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in petitioner's Federal corporate income taxes in the amounts shown below:
Year Ended Deficiency 12/31/64 ........... $ 6,191 12/31/67 ........... 44,586 12/31/68 ........... 148,479
The deficiencies resulted from a determination of the Commissioner that a certain
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