OPINION.
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax of $817.31 and $4,193.86, for the calendar years 1949 and 1950, respectively. In their petition, petitioners seek a determination that there have been overassessments of $1,399.06 and $7,987.30 for the years 1949 and 1950, although the basis for the claimed overassessments is not clear.
The sole issue raised by the pleadings is whether petitioners were taxable...
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