OPINION.
MULRONEY, Judge:
In these consolidated cases respondent determined deficiencies in income tax for the year 1952 of petitioner James E. Walsh (Docket No. 57763) in the sum of $2,596.15, and of petitioner James A. Walsh (Docket No. 60786) in the sum of $1,778.08. After the trial and submission of Docket No. 57763 the petitioner James E. Walsh died and thereafter by order of the Court, the Estate of James E. Walsh, Deceased, Portland Trust Bank...
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