Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in income tax against petitioner and his wife as follows:
Year Deficiency Kenneth C. Davis ........... 1946 $ 910.77 1947 1,124.08 Kenneth C. Davis and Pauline W. Davis .................. 1948 21,375.82 Pauline W. Davis ........... 1946 910.77 ...
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