Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent determined deficiencies in petitioners' income taxes as follows:
Petitioner Docket No. Year Deficiency John E. Fowler.. 4398-64 1959 $29,058.05 1960 5,179.05 Dixie Fowler.... 4226-64 1959 16,580.53 1960 4,153.00 1961 1,760.01...
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