Memorandum Findings of Fact and Opinion
HARLAN, Judge:
These cases, which were consolidated, involve the income and victory tax liabilities of the above named petitioners for the taxable year 1943. The asserted deficiencies are $16,561.12 in the case of James F. Patton, and $16,361.80 in the case of Vincent Patton.
The returns of the petitioners were filed with the collector of internal revenue for the 18th district of Ohio at Cleveland, Ohio.
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