TANNENWALD, Judge:
Respondent determined a deficiency in the amount of $212,354.52 in the Federal income tax of petitioner for the taxable year ended December 31, 1961. After concessions and agreements with respect to various adjustments raised by the deficiency notice, the issues remaining are: (1) Whether the additional examination of petitioner's records and the issuance of a deficiency notice thereunder were improper under section 7605;
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