Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the fiscal years ended July 31, 1955, and July 31, 1956, in the amounts of $8,151.47 and $164,403.68, respectively.
The deficiency for the fiscal year ended July 31, 1955, except that portion due to certain agreed adjustments, and a part of the deficiency for the fiscal year ended July 31, 1956, result from a disallowance in each...
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