Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in petitioners' income tax for the calendar year 1945 in the following amounts:
Docket Petitioners Deficiency 40587 Floyd W. and Madeline W. Bell ................. $49,184.00 40588 Earl W. and Dorothy E. Hosler ............... 8,085.38
The issue is whether petitioners...
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