Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined deficiencies in income tax for the year 1954, in the following cases which were consolidated for trial:
Dkt. No. Deficiency 67433 William I. and Gladys T. Coddington ........... $ 6,180.78 67434 Dabney M. and Martha J. Coddington ............ 58,677.11
The petitioners in Docket No. 67433...
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