Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The Commissioner determined deficiencies in the individual petitioners' income taxes as follows:
Calendar Year Deficiency 1961 ................. $ 4,451.55 1962 ................. 42,757.21 1963 ................. 85,793.92
He also determined deficiencies in the income taxes of petitioner-corporation in the following amounts:
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