Memorandum Findings of Fact and Opinion
ATKINS, Judge:
These proceedings involve deficiencies in income tax for the years and in the amounts as follows:
Dkt. No. Year Deficiency 57321 .......... 1951 $ 349.60 57322 .......... 1951 319.60 61025 .......... 1952 3,460.03 61026 .......... 1952 3,208.02
The proceedings were consolidated for hearing.
The only issue...
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