DRENNEN, Judge:
Respondent has determined deficiencies in petitioners' income tax in Docket No. 65794 for the years 1951, 1952, and 1953 in the amounts of $29,545.10, $32,134.08, and $17,974.86, respectively, and in Docket No. 71133 for the year 1954 in the amount of $24,957.92. By amended petition in Docket No. 65794, petitioners claimed overpayments of tax in 1951, 1952, and 1953 of $1,356.40, $56.94, and $4,609.30, respectively.
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