Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income tax for the years 1958, 1959, 1960 and 1961 in the respective amounts of $6,971.97, $3,490.88, $108.80 and $61,332.47. The years 1958 and 1959 are involved because of the disallowance of a net operating loss carryback. Petitioner concedes the 1960 deficiency in the sum of $108.80.
The issues are (1) whether certain payments made by petitioner...
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