MURDOCK, Judge:
The Commissioner determined a deficiency of $991.70 in income tax for the calendar year 1944. The facts have been stipulated. Two issues are presented for decision. They both relate to income taxable under section 107 (a) of the Internal Revenue Code. The first is whether all or only 25 per cent of the tax attributable to the part of the income allocable to 1942 is to be considered...
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