Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income taxes for the calendar years 1962 and 1963 in the amounts of $254.15 and $514.56, respectively. In its petition, petitioner claimed overpayments in the amounts of $7,086.34 and $6,688.81 for the calendar years 1962 and 1963, respectively.
The sole issue for decision in this case is whether petitioner was availed of during the years here...
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