Memorandum Opinion
WITHEY, Judge:
The Commissioner determined deficiencies in the income tax of petitioners as follows:
Amount Taxpayer 1951 1952 Frank, Sr., and Gladys Cowden ..................... $126,624.97 $52,307.20 Frank, Jr., and June Cowden ..................... 24,060.05 5,907.12 Courtney Cowden ......
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