JOHNSON, District Judge.
These two cases consolidated for hearing and decision are proceedings for the redetermination of deficiencies in the petitioners' income taxes for the calendar year 1920, in the following amounts: William J. Kyle, $1,796.12; and Patrick D. Reinhart, $1,509.08.
The facts were correctly found by the Board of Tax Appeals, as follows:
"The petitioners, attorneys at law, residing in Waynesburg, Greene County, Pennsylvania, in 1908...
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