Memorandum Opinion
RAUM, Judge:
The Commissioner, pursuant to section 1441(a) of the Internal Revenue Code of 1954, determined deficiencies in the following amounts against petitioner for the years 1965 through 1967 in respect of his failure to withhold tax at source on payments of income to a nonresident alien individual:
Year Deficiency 1965 ........... $336 1966 ........... 336 1967 ........... 381 ...
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