OPINION.
MULRONEY, Judge:
The Commissioner determined a deficiency in the petitioners' income tax in the amount of $5,774.72 for the year 1949, and in the amount of $516.52 for the year 1950.
All of the stipulated facts are herein incorporated by this reference.
William H. Goodrich and his wife, Llelven, filed joint income tax returns for the years involved with the then collector of internal revenue
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