Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in the Federal income tax return of the petitioner in the amount of $1,467,536.51 for the taxable year 1962. The issues for our decision are as follows:
1. Whether the petitioner must include in his income for the taxable year 1962 unauthorized withdrawals that he made from E.L. Bruce Co., Inc.
2. If so, what amount...
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