Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the petitioners' income taxes as follows:
Docket Taxable No. Petitioners Year Deficiency 1991-65 George D. and Virginia H. Rowan ............ 1960 $ 266.70 1992-65 George D. Rowan ....... 1961 313.24 ...
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