Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent has determined deficiencies in the income taxes of the petitioners as follows:
Amount of Year Deficiency 1962 ................. $26,780.15 1963 ................. 754.94 1964 ................. 1,142.38
Petitioners have conceded the issues of gain on the liquidation of the corporation herein...
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