Memorandum Opinion
HILL, Judge:
Respondent determined a 1939 income tax deficiency of $232.76 against both petitioners and a 1940 income tax deficiency of $1920.38 against petitioner, D. Somers Clarke alone. The parties have stipulated that we may enter a decision as to the 1939 deficiency in the amount determined by respondent. Hence, there remains for redetermination only the 1940 deficiency against D. Somers Clarke. The sole question is whether respondent...
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