TRAIN, Judge:
Respondent determined a deficiency in income tax of petitioner for the year 1953 in the amount of $8,164.82. The petition alleged error on the part of respondent with regard to the deficiency determination and, in addition, alleged overpayments of taxes resulting from the overstatement of dividend income in 1953 by the amount of $164,000. It has since been agreed that petitioner overstated its dividend income for 1953 by the alleged amount
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