OPINION.
KERN, Judge:
On December 17, 1954, respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1947 in the sum of $493,501.54. In the statement attached to the notice of deficiency respondent explained this action by saying that a purported consolidated return filed for the taxable year by petitioner's parent corporation (Empire South American Industries, Inc.), which included therein the income of petitioner...
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