Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for the calendar years 1963 and 1964 in the amounts of $7,438.03 and $5,120.06, respectively.
The issue for decision is whether petitioners in each of the years here in issue are entitled to deductions of part of the amounts which they had on deposit in two uninsured savings institutions which in 1963 filed petitions for reorganization...
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