Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined deficiencies in income taxes of the petitioners, who are husband and wife and filed joint returns in Toledo, Ohio, of $1,033.20 for 1939 and $717.43 for 1940. Apparently the wife is here only because she was a party to the joint return. The case duly came on for trial on the circuit calendar at Cleveland and the petitioners, represented by counsel submitted upon the pleadings and a concededly...
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