Memorandum Findings of Fact and Opinion
INGOLIA, Commissioner:
Respondent determined a deficiency in the petitioners' Federal income tax of $2,100.22 for the taxable year ending December 31, 1966, and $462.33 for the taxable year ending December 31, 1967. Originally, there were several adjustments made by the respondent, all but one of which have been resolved by agreement of the parties. The only remaining
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