Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in estate tax of petitioner in Docket No. 1731-65 in the amount of $107,964.41 and deficiencies in income taxes of petitioners in the years and amounts as follows:
Docket No. Year Deficiency 1228-64 1959 ............... $ 14,735.08 1229-64 1959 ............... 14,567.87 1248-64 1959 ............... 7,647.92...
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