TRAIN, Judge.
Respondent determined deficiencies in petitioner's income tax for the years 1953 and 1954 in the amounts of $363,371.93 and $622,410.13, respectively. Petitioner seeks a determination that it made overpayments of its income tax for those years by reason of additional depreciation of its cost of the affiliation contract and spot advertising contracts which petitioner failed to claim in its returns.
The issues presented are:
(1)...
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