Memorandum Findings of Fact and Opinion
In the two consolidated cases, respondent determined deficiencies in income taxes for the year ended December 31, 1936 as follows:
Joseph E. Sorg ......... $22,129.80 Walter Lipford ......... 19,499.40
In docket No. 102928, the petitioner, Joseph E. Sorg, died after the filing of the petition, and his personal representatives were substituted as petitioners.
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