Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax as follows:
Taxable Year Deficiency 1963 ................. $14,781.45 1964 ................. 21,316.82 1966 ................. 19,676.99 1967 ................. 1,613.17
The years 1963 and 1964 are involved solely by reason of claims for net operating...
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