PIERCE, Judge:
The Commissioner determined deficiencies in the income taxes of the petitioners for their taxable calendar years 1952 and 1953, in the amounts of $862,429.85 and $64,940.08, respectively; and he also determined that petitioners are liable for an addition to tax for the year 1952 in the amount of $52,200.50, for substantial underestimation of estimated income tax for said year.
The basic issue to be decided is: Whether the amounts of ...
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