STERRETT, Judge:
The respondent determined deficiencies in the income tax of petitioners Samuel and Bess Goldberg in the amount of $10,187.95 for the taxable year ended December 31, 1963, and in the corporation income tax of petitioner S. & B. Realty Co. in the amount of $1,119.74 for the fiscal year ended May 31, 1965. These cases have been consolidated for trial due to the relationship of the petitioners and the continuity of the facts involved; however...
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