Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax, including for the years 1952 and 1953 excess profits tax, in the following amounts:
Year Amount 1952 .............. $537,724.50 1953 .............. $537,724.50 1954 .............. $398,454.20
The primary determination...
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