Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies and additions to tax in petitioners' income tax as follows:
Addition to Tax, Sec. 6653(a), Year Deficiency I. R. C. 1954 1965 ...... $ 2,013.94 $100.69 1966 ...... 13,697.44 684.87
The principal issue is whether two apartment houses owned by petitioner Peter R. Shibley...
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