Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined a deficiency in income tax of $313, with interest, against Frank E. McDevitt for the calendar year 1948. The only question for our determination is whether the petitioner is entitled to claim his three children as dependents in the calendar year 1948. The petitioner's income tax return for 1948 was filed with the collector of internal revenue for the district of Iowa.
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