Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
These consolidated proceedings involve deficiencies in income tax of Frank Scotto, deceased, for the calendar year 1944 and the taxable fractional year ended June 10, 1945, in the respective amounts of $1,703.02 and $2,439.68.
The sole issue presented by both cases is whether the Commissioner erred in adding to the net income of the decedent the amounts of $6,051.43 and $9,716.12 for the years...
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