Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the income tax of Plantation Patterns, Inc. (docket No. 3962-68) and Mr. and Mrs. John S. Jemison, Jr. (docket No. 3967-68) as follows:
Docket Taxable Number Year Ended Deficiency 3962-68 September 30, 1963 ......... $ 39,175.971 3962-68 September 30, 1964 ............
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