Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in the income taxes of petitioners as follows:
Docket No. Petitioner Year Amount 2645-66 Samuel Horowitz and 1961 $18,225.51 Carol P. Horowitz 2646-66 Samuel Horowitz ....... 1962 7,149.16 1963 2,728.21 2647-66 Carol...
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