Memorandum Opinion
HARRON, Judge:
The respondent determined a deficiency in income tax for the year 1937 in the amount of $10,794.61. At the hearing, by his answer to petitioner's amended petition, respondent claimed that the deficiency should be increased to $22,278.98. Petitioner contends that there is no deficiency and that tax has been overpaid in the amount of $118,466.87.
Petitioner filed its income tax return with the collector for the second...
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