Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the Federal income tax due from petitioners as follows:
Year Deficiency 1958 ................. $ 2,270.09 1959 ................. 32,489.80 1960 ................. 22,170.04 1961 ................. 18,153.58
Respondent concedes that petitioners' income for the taxable year 1958 should not...
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