Memorandum Opinion
VAN FOSSAN, Judge:
J. H. Daughtry and Allie Daughtry, the original petitioners, were husband and wife, residing in the State of Florida. J. H. Daughtry died in January of 1955 and his administrator, Cecil Daughtry, was substituted as a petitioner. The deficiencies in income tax determined by respondent are as follows:
Year Deficiency 1948 .................. $ 853.56 1949 .....................
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