ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1952 in the amount of $29,215.89, and by amendment to his answer asserted a claim for an increase of $4,630.64 in the deficiency. The petitioner alleged an overpayment of the tax by the amount of $16,407.97.
The principal question presented is whether, as determined by the respondent, the amount of an award by the Motor Carrier Claims Commission received by the...