Memorandum Findings of Fact and Opinion
TANNENWALD, Chief Judge:
Respondent determined the following income tax deficiencies:
Taxable Petitioner Year Amount Phyllis Ginsberg .......... 1976 $456.54 Philip Ginsberg ........... 1976 $311.42
The issues to be decided are (1) whether petitioner Phyllis Ginsberg (Ms. Ginsberg) or petitioner Philip Ginsberg (Mr. Ginsberg...
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