Memorandum Opinion
JOHNSON, Judge:
This proceeding involves a deficiency of $7,434.65 in income tax for 1950.
All of the facts are stipulated and are so found.
[Findings of Fact]
Petitioners, husband and wife, filed a joint return for the taxable year with the collector of internal revenue for the first district of Missouri. Petitioner Samuel H. Liberman, an attorney at law at all times
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