Memorandum Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax for 1962 and 1963 in the amounts of $3,557.50 and $4,249.45 against petitioners Donald J. and Iva M. Wallace (husband and wife) and in the amounts of $3,693.64 and $4,447.19 against petitioner Guy P. Bert. The Wallaces had filed joint returns and Bert separate returns for those years. During the taxable years the male petitioners owned, in equal shares, all of the outstanding...
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