OPINION.
BLACK, Judge:
The Commissioner has determined deficiencies in petitioner's income tax of $3,346.15 for the calendar year 1944 and $1,851.79 for the period January 1 to October 31, 1945. The deficiency for the year 1944 is due to four items being included in petitioner's net income, namely:
(a) Dividends ----------------------------------------- $2,650.00 (b) Interest ------------------------------------------ 500.00 ...
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