Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Petitioner Taxable Year Ending Deficiency Joseph and Mary Perrotto .............. December 31, 1970 $ 481.42 Crystal Motor Lodge, Inc. ............. October 31, 1970 12,493.04
Because of concessions made by the parties, only...
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