Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar years 1959, 1960, and 1961 in the amounts of $916.58, $592.08, and $13,100.85, respectively, and an addition to tax under section 6653(b), I.R.C. 1954,
The issues for decision are:
(1) Whether J. Vincent Keogh is collaterally...
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