Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax against the petitioners in the amount of $128.42 for the year 1962. Petitioners claim an overpayment of $852.99 in income taxes for the same year. Each party has conceded certain issues raised in the notice of deficiency. These concessions will be given effect under Rule 50.
The sole remaining issue is whether under section 1001(a) of the...
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