Memorandum Opinion
TYSON, Judge:
This proceeding involves income tax deficiencies determined by respondent against petitioner and also petitioner's claimed overpayment of income taxes for the calendar years and in the amounts as follows:
Claimed Year Deficiency Overpayment 1938................ $ 5,192.50 $46,334.12 1939................ 55,576.12 ......... 1940......
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