OPINION.
RAUM, Judge:
The Commissioner determined a deficiency in the amount of $23,027.16 in income tax of A. W. SoRelle (sometimes hereinafter referred to as SoRelle) for 1945. The present case grows out of an earlier case, Docket No. 36411, which involved SoRelle's income taxes for 1946 and 1947. He had died in 1949, and the petitioner in both cases is the same, namely, his estate. The earlier proceeding was consolidated with two others and is...
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