OPINION.
ARNOLD, Judge:
These consolidated proceedings involve deficiencies in income tax of decedent Benjamin Lowenstein as follows:
Docket No. 111414, 1936 ------------------------------- $62,507.91 Do ------------ 1938 ------------------------------- 51,165.30 Docket No. 104543, 1937 ------------------------------- 8,479.69
In Docket No. 104543 the respondent disallowed...
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