OPINION.
MULRONEY, Judge:
Respondent determined deficiencies in income taxes of Elmer B. Boyd for the taxable years 1949 and 1950 in the amounts of $1,878.43 and $2,691.17, respectively. Subsequent to the issuance of the notice of deficiency, but before the filing of the petition in this case, Elmer B. Boyd agreed to a part of the deficiencies in amounts of $654.72 for the year 1949 and $2,056.81 for the year 1950 and said sums were paid, thus leaving...
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