Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined the following deficiencies in income tax of petitioner:
Fiscal Year Ended Deficiency1 May 31, 1960 ........... $ 2,674.72 May 31, 1961 ........... None May 31, 1962 ........... 50,787.30 May 31, 1963 ........... None May 31, 1964...
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