Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income tax against petitioners for the calendar years 1938 and 1939 in the amounts of $7,162.13 and $326.08, respectively. The only taxes in controversy are those for the year 1938.
In a statement attached to the deficiency notice the respondent made adjustments to the net income reported by petitioners in their joint income tax return for the year 1938 as follows:
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