Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:
Addition to Docket Tax Sec. No. Year Ended Deficiency 6651(a) 4643-66 ..... Oct. 31, 1961 $23,744.42 ........ 4643-66 ..... Oct. 31, 1962 42,291.12 ........ 4643-66...
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