OPINION
TANNENWALD, Judge:
The respondent determined deficiencies in the petitioners' income tax for the calendar years 1960, 1963, and 1964 in the respective amounts of $35,435.63, $343.25, and $16,262.54. All of the facts have been stipulated by the parties and accordingly the proceeding was submitted under Rule 30 of the Court's Rules of Practice.
At the time of filing their petition, J. Meredith Siple and Delia W. Siple, husband and wife...
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