PIERCE, Judge:
This proceeding involves 32 separate but related cases, which were consolidated for trial before this Court. In the first of these (Comtel Corp., docket No. 225-63), the respondent determined a deficiency of $215,621.33 in the income tax of petitioner Comtel, a dissolved corporation, for its fractional taxable year covering the period from February 1, 1958, to September 30, 1958. In each of the other 31 consolidated cases, the respondent determined...
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