Memorandum Findings of Fact and Opinion
FISHER, Judge:
This proceeding involves deficiencies in income tax determined by respondent as follows:
Year Ended Deficiency 6-30-51 .................. $17,119.44 6-30-52 .................. 12,333.20 6-30-53 .................. 20,086.60
The issues presented are as follows: (1) whether petitioner was availed of in each of the taxable years involved for the...
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