Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioners' income tax for the calendar year 1939 in the amount of $13,438.64.
After this proceeding was instituted, petitioners made an additional payment in the amount of $5,000 on account of the tax, and amended their petition at the hearing to ask for a determination that there had been an overpayment of tax in the amount of $5,000.
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