WILES, Judge:
Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:
Year Deficiency 1960 -------------------- $3,053.38 1961 -------------------- 121,168.00 1963 -------------------- 22,757.00
Some of the issues have been settled by the parties. The issues remaining for decision are:
(1) Whether petitioner...
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