Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The respondent determined deficiencies in the income tax of petitioners for the calendar year 1943 as follows:
Welker J. Smucker ......... $ 7,546.97 Willard E. Smucker ........ 19,373.70 J. M. Smucker ............. 7,894.31
Due to the application of Section 6, Current Tax Payment Act of 1943, petitioners' income for the year 1942 is involved in these proceedings...
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