Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in income tax and additions to the tax against the petitioner, Dennis D. Carlin, for the years 1945, 1946, and 1947, and against the petitioners, Dennis D. Carlin and Blanche (Steinberg) Carlin, for the years 1948, 1949, and 1950, as follows:
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