Memorandum Findings of Fact and Opinion
HOYT, Judge:
The respondent determined deficiencies in petitioners' income taxes for the years 1958 and 1959 of $2,166.35 and $2,484.63, respectively. He also asserted a 5 percent negligence penalty under section 6653(a) of the 1954 Code. It was stipulated that there was no section 6653(a) penalty owed and as a result of concessions by the parties and the abandonment of issues at trial and on brief, the only remaining...
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