Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined deficiencies in income taxes due from the petitioners as follows:
Year Deficiency December 31, 1965 ............ $3,107.07 December 31, 1966 ............ 4,434.54 December 31, 1967 ............ 1,248.90
As a result of concessions made by the parties, the only issue remaining for decision is whether petitioner sustained...
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