Memorandum Findings of Fact and Opinion
OPPER, Judge:
Petitioner contests the determination of deficiencies in income tax and claims overpayments as follows:
Year Deficiency Claimed Overpayment 1953........ $119.20 $ 775.56 1954........ 73.55 337.40 1955........ 24.44 ........ _______ ________ $217.19 $1,112.96
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