Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined the following deficiencies in income taxes against the petitioners:
1957 ............ $ 8,854.72 1958 ............ 7,205.06 1959 ............ 22,347.23
Petitioners conceded that they received dividend income in 1958 and 1959 in the respective amounts of $3,261.05 and $3,552, as a result of personal usage of an airplane of Vulcan-Cincinnati, Inc...
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