CAMERON, Circuit Judge.
Petitioner, Commissioner of Internal Revenue, issued a deficiency assessment against the Respondents, Robillard, for the year 1957 in the amount of $231.36. With their joint federal income tax return for the calendar year 1957, the Respondents showed an amount of $1,972.62 of retroactive adjustment of earnings for the period January 1, 1955 through December 1, 1956,
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