Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies in the petitioner's income tax of $439.54 for the taxable year 1962 and $376.10 for the taxable year 1963. The sole issue for decision is whether the petitioner provided more than one-half of the total support of each of her three grandchildren in the years 1962 and 1963 within the meaning of section 152(a) of the Internal Revenue Code of 1954
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