Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency in income and excess profits tax has been determined by the Commissioner against the petitioner for the taxable year 1951 in the amount of $261,050.38 and an addition to tax for delinquency in the filing of a return for such year in the amount of $65,262.60. The petitioner does not allege error in its petition with respect to the addition to tax. The issues under the pleadings are (1) whether...
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