Memorandum Findings of Fact and Opinion
HOYT, Judge:
Respondent determined a deficiency in petitioners' income tax for 1964 in the amount of $534.36. Because of a credit of $150.90 under section 31 of the 1954 Code for taxes withheld on wages in excess of the tax liability shown on the return, the statutory notice reflects a net deficiency in payment of $383.46. The parties agreed at trial that this is the correct net deficiency in payment.
The sole...
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