Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $809.64 in petitioners' Federal income tax for the year 1962 and an addition to tax under section 6653(a), Internal Revenue Code of 1954, in the amount of $40.48. At issue is whether two deposits — the first for $3,000 made on January 2, 1962, and the second for $400 made on September 11, 1962 — in petitioners' savings account at the First Federal Savings...
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