Memorandum Findings of Fact and Opinion
BRUCE, Judge:
This proceeding involves deficiencies in income tax determined by respondent for the years 1948, 1949, and 1950 based upon certain transactions occurring in 1946 with respect to the interest of Ben P. Gale in the Universal Plating Company. The deficiencies determined are as follows:
1948............. $ 753.76 1949............. 2,696.54 1950............. 2,667.74
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