OPINION.
BLACK, Judge:
This proceeding involves the determination by the respondent against petitioner of a deficiency of $8,289.44 in income tax for the calendar year 1941, a small part of which is not contested.
The deficiency is the result of a minor adjustment of $1, not contested, and of an addition to income of $17,016.85 which the respondent, in a statement attached to the deficiency notice, explained as follows:
(a) It is held...
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