Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Russell S. Roberson, Jr., and his wife Gerry C. Roberson, filed a joint Federal income tax return for the calendar year 1958 with the district director of internal revenue, Birmingham, Alabama. Petitioner filed his individual Federal income tax return for the calendar year 1959 with the same district director. Statutory deficiency notices bearing the same date were directed to petitioner and his wife...
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