Memorandum Findings of Fact and Opinion
PIERCE, Judge:
Respondent determined deficiencies in the income taxes of the petitioners, as follows:
Docket Taxable No. Petitioner year Deficiency 71279 Langeloth Townsite Co. ............ 1950 $34,875.00 Yr. ended 71287 Gust J. Barbush 1/31/53 30,694.36
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