Memorandum Findings of Fact and Opinion
WITHEY, Judge:
A deficiency in the income tax of petitioner has been determined by the Commissioner for the fiscal year ended October 31, 1965, in the amount of $44,747.53. The only issue presented is whether respondent has erred in increasing the gross income of petitioner for that year in the amount of $92,583.94 as a liability of petitioner alleged to have been forgiven during that year.
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