Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies have been determined in the income taxes of petitioners by the Commissioner in the amounts of $205.99 and $206 for the respective taxable years 1963 and 1964. The sole issue is whether respondent has erred in disallowing as a nonbusiness bad debt deduction amounts in each year representing one-half the income tax, plus additions thereto for fraud, for a prior year paid by one spouse upon...
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