The respondent determined that petitioners were liable for deficiencies in income tax and penalties under sections 291(a), 293(b), and 294(d)(2) of the Internal Revenue Code of 1939 and corresponding prior statutes for various years extending from 1934 to 1950. The parties have disposed of all issues regarding the deficiencies and penalties and are in agreement that the petitioners have paid an amount in excess of their tax liabilities. The only issue remaining for determination...
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