Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined deficiencies in income tax for the taxable years 1960 through 1963 as follows:
Taxable Year Deficiency 1960 ................ $5,100.00 1961 ................ 7,352.58 1962 ................ 9,800.47 1963 ................ 8,517.30
The two issues for our determination are:
(1) Whether the amounts paid...
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