Memorandum Opinion
WITHEY, Judge:
The respondent determined deficiencies in petitioners' income tax for the years and in the amounts as follows:
Docket No. Year Deficiency A. A. Gallagher Warehousing Corp. ................... 4870-62 1958 $ 2,315.30 1959 12,248.55 American Truck Rental Corp. ......
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