Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax for the year 1960 in the amount of $3,725.36. Petitioner has also been assessed with a penalty in the amount of $208.28 under section 6653(a) of the Internal Revenue Code of 1954.
The only issues for decision are: (1) whether petitioner misappropriated funds belonging to his deceased mother...
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