Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax against petitioner in the amounts of $22,444,39 and $11,576.81 for the fiscal years ending November 30, 1947 and 1948, respectively. The principal issue relates to the Commissioner's disallowance of deductions of $52,000 for the fiscal year 1947 and $34,259.63 for the fiscal year 1948 which petitioner had claimed as casualty losses arising from hurricanes...
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