OPINION.
DISNEY, Judge:
This proceeding, since the filing of a second amended petition, involves income tax for the calendar year 1936, as to which the Commissioner determined a deficiency of $2,725.69; and income and excess profits taxes for 1937, as to which deficiencies of $26,313.86 and $17,204.17, respectively, were determined by the Commissioner. After the hearing and the filing of brief upon the issues originally tendered, and after the passage...
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