WILLIAM AND SIMPSON v. COMMISSIONER

Memorandum Findings of Fact and Opinion Findings of Fact

TRAIN, Judge:

Petitioners are husband and wife residing in Waco, Texas. They filed joint income tax returns for the taxable years 1957 and 1958 with the district director of internal revenue, Austin, Texas, on July 16, 1959. William J. Simpson is hereinafter referred to as petitioner.

Respondent determined deficiencies in petitioners' income tax and additions to tax as follows:

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