OPINION
STERRETT, Judge:
The respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ended September 30, 1958, September 30, 1959, September 30, 1960, and September 30, 1961. The only issue in controversy is whether respondent is entitled to adjust petitioner's Federal income tax liability for those years pursuant to sections 1311 through 1314.
Some of the facts have been stipulated and are so found. The...
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