Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in the income tax of the petitioners for the taxable year 1950 in the amounts as follows:
Julius Callner, Sarah Callner.... $20,778.28 Morris J. Okrent, Esta Okrent.... 20,467.30 Abner E. Kops.................... 26,368.84
The issues for determination are whether the respondent erred in determining that during 1950 petitioners...
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