Memorandum Findings of Fact and Opinion
HOYT, Judge:
This proceeding is for redetermination of deficiencies in petitioners' income taxes for 1957 and 1958 in the respective amounts of $1,287.94 and $6,011.61. Respondent also determined a delinquency penalty of $280.57 for 1958 which petitioners do not contest. The amounts said in the petition to be in controversy are $1,278.08 for 1957 and $5,761.60 for 1958.
The principal question in issue is whether...
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