Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
These cases have been consolidated for trial, briefing and opinion. The respondent determined deficiencies in petitioners' income taxes for the year 1961 as follows:
Deficiency Docket No. 4138-64........... $983.93 Docket No. 4905-64........... 667.38
These consolidated cases present the single, common issue as to whether distributions...
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