Memorandum Findings of Fact and Opinion
OPPER, Judge:
In these consolidated proceedings respondent determined deficiencies in income tax as follows:
Petitioner Year Deficiency Christos Laganas ......... 1947 $10,337.43 Christos Laganas and|..... 1948 6,034.38 > Arhontoula Laganas..|..... 1949 7,611.38
The issues to be decided are: (1) Whether Christos or Arhontoula...
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