Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income tax in these consolidated dockets as follows:
Addittion to Tax Docket Sec. 6651(a), No. Year Deficiency I. R. C. 1954 4351-63 ........... 1960 $7,706.49 $1,926.62 4352-63 ........... 1960 6,387.22 ...
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