Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined a deficiency in petitioner Bertha I. Spinner's Federal income tax of $12,461.74 for 1961 and $9,764.02 for 1962. In the case of Plastic Binding Corporation, he determined a deficiency in Federal income tax of $14,820 for its taxable year ending September 30, 1961, and $7,410 for its taxable year ending September 30, 1962.
In these consolidated proceedings, the issues...
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