Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
In Docket No. 63366 filed by Louis Cohen, respondent determined a deficiency in income tax for the taxable year ended December 31, 1952, in the amount of $4,021.74. In Docket Nos. 63367 and 63368 filed by Hope Cohen and Louis Cohen, respectively, respondent determined joint deficiencies in income tax and additions to the tax for the taxable years ended December 31, 1953, and 1954, as follows:
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