Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the income tax of petitioner J. S. Biritz Construction Co. in the amount of $371.76 for each of its taxable years ended February 28, 1959, and February 29, 1960, and determined a deficiency in the income tax of petitioners Joseph S. Biritz and Dorothy Biritz in the amount of $4,863.65 for the calendar year 1960.
The issues for decision are:
(1) Whether...
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