Memorandum Findings of Fact and Opinion
DISNEY, Judge:
These proceedings were consolidated for hearing and involve deficiencies in income taxes for the years 1943 and 1944 as follows:
Docket Petitioner No. Year Deficiency Charles Goodman ...... 14238 1943 $17,234.13 Charles Goodman ...... 18174 1944 13,603.87 Robert Goodman ....... 14239 1943 388...
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