The Commissioner determined deficiencies in petitioner's income tax in the amounts of $60,699.15 and $70,594.59 for the taxable years ending December 28, 1963, and January 2, 1965, respectively, and deficiencies in petitioner's withholding (section 1442(a)) tax in the amounts of $5,836.50 and $7,059.46 for the calendar years 1963 and 1964, respectively. The only issues remaining for decision are: (1) whether the Commissioner properly allocated income to petitioner, pursuant...
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