Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in the income tax of petitioner for the taxable year ended December 31, 1956, in the amount of $7,199.24, for the period ended June 30, 1957, in the amount of $2,724.84, and the fiscal year ended June 30, 1958, in the amount of $17,635.98. An issue raised by the pleadings
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