Respondent determined deficiencies in petitioner's income and excess profits tax of $87,935.72, $220,260.07, and $261,682.44 for the years 1951, 1952, and 1953, respectively. He disallowed petitioner's claim for refund of income and excess profits tax of $193,908.85 for the year 1951.
The issues to be decided are (1) whether petitioner received abnormal income within the meaning of section 456, I.R.C. 1939, during
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