Memorandum Opinion
RAUM, Judge:
Petitioners are husband and wife, and reside at 51 East 67th Street, New York, New York. They filed their joint income tax returns for the years in issue with the district director of internal revenue, Upper Manhattan District, New York. The Commissioner determined deficiencies in income tax against them as follows:
Year Deficiency 1953 ............... $ 738.44 1954 ............... ...
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