Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in the income tax of petitioners for the taxable years 1957 through 1961 have been determined by respondent in the respective amounts of $6,439.26, $5,960.58, $1,697.60, $432.99, and $2,620.58. The parties have settled all issues raised by the pleadings with one exception which presents the question whether respondent has erred in treating certain advances made to petitioner Paul Berthold...
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