Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income tax as follows:
Addition to Docket Tax, § 6653(a), Number Year Deficiency I. R. C. 19541 3543-66 1962 $10,771.55 $538.58 3544-66 1963 12,593.02 629.65
The issues in these consolidated...
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