STERRETT, Judge:
In his notice of deficiency dated November 2, 1979, respondent determined deficiencies in petitioner's Federal income taxes for the taxable years ended March 31, 1973, and March 31, 1974, in the respective amounts of $305,499.34 and $2,484.48. After concessions by the parties, the sole issue remaining for decision is whether, pursuant to sections 38 and 48(d), I.R.C. 1954, U-Haul International, a subsidiary corporation of petitioner, is entitled...
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