This proceeding involves deficiencies in income tax of $9,527.79 for the year 1948 and of $8,153.48 for the year 1949 determined against Leon Mandel (hereinafter referred to as the petitioner) and Carolina Panerai Mandel, his wife. On August 4, 1952, petitioners consented to the assessment and collection of $6,962.07 of the total deficiencies asserted for the 2 years.
The issues to be determined are: (1) Whether the amounts of $4,583.31 and $7,083.31 paid by petitioner...
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