Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined deficiencies in the income tax of petitioners for the years 1950, 1952, and 1953 as follows:
Year Deficiency 1950 .................. $ 4,568.44 1952 .................. 78,670.12 1953 .................. 101,972.96
The issues presented for our decision are (1...
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