Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $325.23 and $372.19 in the income taxes of the petitioner A. B. Innis for the years 1938 and 1939, respectively, and deficiencies of $328.23 and $372.08 in the income taxes of the petitioner Jean B. Innis for the same respective years. He also found an over-assessment of $59.51 for the year 1940 in favor of each of the petitioners.
The following issues are presented:
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