OPINION.
HARRON, Judge:
The respondent determined deficiencies in income tax for the taxable year 1952 as follows:
Docket No. Petitioners Deficiencies 64451 Danny Kaye and Sylvia Kaye -------------------- $19,667.66 64452 Cy Howard ------------------------------------- 33,452.93
Each deficiency results from the respondent's disallowance of...
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