Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the calendar year 1963 in the following amounts:
Docket No. Petitioner Deficiency 2645-68 Gunther J. Shirley and Helen A. Shirley .................... $11,023.71 2653-68 William E. Cornell and Louise S. Cornell .......................
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