Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
This proceeding involves income tax deficiencies for 1945 and 1947 in the respective amounts of $1,099.64 and $1,768.88 determined against Charles R. Whitworth and Sarah M. Whitworth. Sarah M. Whitworth died subsequent to the filing of the petition herein and Charles R. Whitworth, Executor of the Estate of Sarah M. Whitworth, was substituted as a petitioner. The sole issue is whether the sum of $12...
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