Memorandum Findings of Fact and Opinion
Respondent determined deficiencies of $3,838.38 and $7,455.60 in petitioners' income tax for the calendar years 1955 and 1956, respectively. The deficiencies arose as a result of respondent's determination that credits to reserve accounts totaling $14,546.22 during 1955 and $16,054.83 during 1956 constituted taxable income to petitioners.
The amounts in dispute, as set forth in the notice of deficiency, consisted of...
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