Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the Federal income tax of petitioners Everett H. O'Dowd and Cornelia N. O'Dowd for the calendar year 1969 in the amount of $153,853.90 and determined a deficiency in Federal income tax of Robinson Water Company for the calendar year 1969 in the amount of $21,248.43. In an amended petition the O'Dowds claimed an overpayment of income tax for the year 1969 in the amount...
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