The Commissioner determined a deficiency in income tax in the amount of $86,095.42 for the year 1941. The questions involved are whether the tax liability of petitioner for 1941 is determinable under the provisions of section 107 (a) of the Internal Revenue Code, and, if so, whether the income of petitioner apportionable to 1936 and 1937 under the provisions of section 107 (a) is excludible from his gross income under the provisions of section 116 (a) of the Internal Revenue...
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