Memorandum Findings of Fact and Opinion
OPPER, Judge:
Deficiencies in income tax of petitioners Francis X. Heidl and Theresa J. Heidl for 1958 and 1959 in the amounts of $835.93 and $71.88, respectively, and of petitioner Heidl's, Inc., for the fiscal year ending March 31, 1959 in the amount of $936.41 have been determined.
All other items having been conceded on brief, the only issue to be decided is whether the payment by petitioner Heidl's, Inc...
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