Memorandum Findings of Fact and Opinion
Respondent determined income tax deficiencies against the petitioners for the calendar years 1953 and 1955 in the respective amounts of $22,524.80 and $461.95.
While the prayer in the amended petition asks that this Court find "that the petitioners owe no additional taxes for the years 1953 and 1955," there is no allegation of error with regard to the latter year and no reference was made to that year at the trial...
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