Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined a deficiency in petitioner's income tax of $6,982.53 for the taxable year 1960. Subsequently, respondent determined a deficiency in petitioner's income tax of $3,283.79 for the taxable year 1963. On joint motion of the parties, the two matters were consolidated for the purpose of their submission under Rule 30 of the Tax Court Rules of Practice.
The issues for decision are...
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