The respondent determined a deficiency in income tax of petitioner in Docket No. 52544, for the year 1946, in the amount of $73,677.25 and an addition to the tax for failure to file a return for such year. Respondent also determined a deficiency in income tax of petitioners in Docket No. 52545, for the year 1947, in the amount of $18,694.44. At the trial, respondent was granted leave to amend his answer to claim, in the alternative, an increased deficiency for the year 1947...
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