OPINION.
TIETJENS, Judge:
The respondent determined deficiencies in income tax against Angeles Corral and Mary Jo Corral O'Brien for the calendar years 1947 and 1948, and against Anthony Florez and Eva Florez, his wife, for the calendar year 1948. As to all other petitioners the respondent determined deficiencies for the calendar year 1947. The petitioners have waived any issues raised by these appeals as to the year 1948. The sole issue is whether...
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