Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent determined deficiencies in Federal income taxes against petitioner for the fiscal years ended June 30, 1952, and June 30, 1953, in the respective amounts of $335.24 and $150. Petitioner alleged error on the part of respondent with regard to such determination and, in addition, claims overpayments of such taxes in
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