Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax against the corporate petitioner for the taxable years 1957 and 1962 in the respective amounts of $2,394.34 and $5,781.39, and additions to tax under section 6653(a) of the Internal Revenue Code of 1954 for such taxable years in the respective amounts of $119.72 and $289.07. He determined deficiencies in income tax against the individual petitioners...
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