Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioner for the taxable year 1959 in the amount of $3,700.23 and an addition to tax under section 6651(a) of the Internal Revenue Code of 1954 in the amount of $197.71.
All issues raised by the pleadings with the exception of that below stated have been conceded, leaving remaining to be decided the sole issue whether respondent...
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