Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for the years 1959 and 1962 as follows:
Docket No. Petitioners 1959 1962 6035-64 Irving and Ida Ninberg ..... $5,012.74 $1,726.51 6036-64 Ben and Mollie Ninberg ..... 6,365.71 396.30
The only issue for determination is...
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