MEMORANDUM OPINION
WARREN H. YOUNG, District Judge.
In this suit, petitioners Gustav A. Danielson and Maria Danielson seek a redetermination of their income tax liability for the years 1972 and 1973. Because Maria Danielson is a party only by virtue of having filed a joint return for those years with her husband, references to Danielson will mean Gustav.
I.
Danielson has practiced on the island of St. Thomas as a certified public accountant...
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