MEMORANDUM OPINION
ORMA R. SMITH, District Judge.
As the result of an examination by the agents of the Internal Revenue Service (Agents) of the income tax liabilities of O. B. Crocker and his wife, Ora Crocker, now deceased, (Taxpayers) for the taxable years 1956-1961, inclusive, the District Director of Internal Revenue (Director) on October 27, 1967, issued a thirty-day letter to taxpayers notifying them of the findings of the Agents with regard to the...
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