Memorandum Findings of Fact and Opinion
RAUM, Judge:
Petitioners are husband and wife. They filed their joint income tax returns for 1967 and 1968 with the district director of internal revenue at San Francisco, California. The Commissioner determined deficiencies in petitioners' income tax for those years in the amounts of $528 and $530.53, respectively. At the time of the filing of the petition herein they resided in Sausalito, California. At issue is...
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