Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $5,912.09 in income tax of the Burrells and an addition to tax of $295.60 under Section 6653(a) for negligence for 1962, and deficiencies in income tax of Engine Rebuilders, Inc., of $2,128.70 and $1,559.94 for its fiscal years ended October 31, 1963 and 1964.
The Burrells allege that the Commissioner erred in (1) determining $10,899.27 representing "Customer Core Deposits...
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