OPINION
FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $532,874.53 and $126,178.29 in petitioner's Federal income tax for 1969 and 1970, respectively. Petitioner did not contest the determination of the deficiency for 1969; other issues having been settled by the parties, the issues remaining for decision as to the 1970 taxable year are as follows:
(1) Whether the foreign tax credit allowable in respect of Western...
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