Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined deficiencies in petitioner's federal income taxes for the calendar years 1969 and 1970 in the amounts of $9,041.69 and $3,669.25, respectively. In an amendment to his answer to the petition, respondent asserted that petitioner was liable for a deficiency in income tax for the calendar year 1970 in the amount of $7,660.02 in the event that we uphold petitioner's position with respect...
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