Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent determined deficiencies in the income tax of the petitioners for 1957 as follows:
Petitioner Docket No. Deficiency Manuel G. Setal....... 78808 $198.00 Juan Diaz ............ 79912 524.97
The only issue presented for our decision is the correctness of the respondent's action in determining that petitioners improperly...
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