Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined the following deficiencies in petitioner's Federal income taxes:
TYE Deficiency 12/31/69 ............ $23,301.14 12/31/70 ............ 38,861.98
Petitioner claims that it is entitled to refunds in the amounts of $10,107.56 and $3,360.45, respectively, of its 1969 and 1970 taxes. Because of concessions by both parties, the...
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