Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income tax for the calendar years 1961 and 1962 of petitioners in docket No. 2189-66 of $126,332.45 and $7,514.21 respectively, and in docket No. 2190-66 of $124,689.39 and $7,088.35 respectively. These adjustments made by the respondent reflect the inclusion by him in the income of the petitioners of the distributable share of the income of the Novinger Company, Inc., determined by...
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