Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined the following deficiencies in the income tax of petitioner:
Taxable Year Ended Deficiency Dec. 31, 19581 ................... $31,773.15 Dec. 31, 1959..................... 28,019.67 Dec. 31, 1960..................... 16,978.631 Part of the 1958 deficiency is due to the disallowance...
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