Memorandum Findings of Fact and Opinion
TURNER, Judge:
Respondent determined deficiencies in income tax against the petitioners as follows:
Year Ended Deficiency January 31, 1964 ......... $ 726.98 January 31, 1965 ......... 7,646.85
The petitioners have claimed a refund for the taxable year ended January 31, 1964, in the amount of $2,236.13.
The question for determination, both with respect...
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