Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' income tax for the taxable years ended October 31, 1960 and 1961, in the amounts of $8,276.44 and $18,845.94, respectively, and an addition to the tax under the provisions of section 6651(a) of the Internal Revenue Code of 1954 for the taxable year ended October 31, 1961, in the amount of $3,469.20. The parties have disposed of certain issues raised in...
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