These consolidated proceedings involve income tax deficiencies for the calendar year 1939. In Docket No. 9012, respondent determined a deficiency of $560,210.90 against petitioner Paulina duPont Dean. In Docket No. 9013, respondent determined a deficiency of $123,340.92 against petitioner J. Simpson Dean. Petitioners claim overpayments in the respective amounts of $103,752.99 and $22,057.87. The issues submitted are:
1. The extent to which the respective petitioners...
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