FAY, Judge:
The respondent determined deficiencies in the income tax of petitioners William E. and Georgie Gabriel for the taxable years ended December 31, 1956 and 1957, in the respective amounts of $29,651.18 and $82.56. Respondent also determined a deficiency of $146.19 in the income tax of petitioner W. E. Gabriel Fabrication Co. for the taxable year ended December 31, 1957. William E. Gabriel will hereinafter be referred to as petitioner.
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