Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in Federal income tax liability of petitioner and his wife for the year ended December 31, 1953, in the sum of $246.90. The petition filed herein consisted of an informal letter which did not adequately state the issues. There was attached to the respondent's answer a copy of the deficiency notice mailed to petitioner and his wife, but the statement attached to the deficiency notice merely...
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