Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in the income tax of the petitioners for 1949 as follows:
Docket No. Deficiency Jack Showell ........ 48153 $3,946.65 Dorothy Showell ..... 48154 4,065.69
These deficiencies resulted from the respondent's determination that each of the petitioners...
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