DRENNEN, Judge:
Respondent determined deficiencies in income tax against petitioner for the calendar years 1950 and 1952 in the amounts of $17,410.76 and $1,797.30, respectively. Petitioner claims an overpayment in 1952 in the amount of $500.93 based upon an additional deduction of $963.34 for State income taxes, the right to which respondent concedes.
The only issue is whether petitioner's accounts receivable due from related corporations to which...
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