Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioner's income tax for the taxable years 1959 and 1960 in the amounts of $76,594.97 and $99,118.94, respectively. Prior to trial the parties disposed of certain issues raised by respondent in his deficiency notice by agreeing to various adjustments. The only issue remaining for decision is whether any of the income of a wholly-owned subsidiary of petitioner...
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