Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
These cases were consolidated for trial, briefing, and opinion. The respondent determined deficiencies in the petitioners' income taxes as follows:
Docket No. Year Deficiency 5357-63 1960 ............... $31,013.29 1961 ............... 3,469.48 Docket No. Fiscal Year Ending Deficiency...
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