IRWIN, Judge:
Respondent determined a deficiency in petitioner's income taxes for the years 1965 and 1966 in the amounts of $85,434.31 and $90,105.22, respectively. Because of concessions stipulated by both parties prior to trial, only one issue with respect to the application of section 482 remains for decision. A computation under Rule 50 will be necessary to reflect the pretrial concessions and the ultimate resolution of the remaining issue in the case....
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