Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in the Federal income tax due from the petitioners as follows:
Year Deficiency 1958 ................... $ 2,040.25 1959 ................... 143,854.90 1960 ................... 52,819.26 1961 ................... 31,496.77 1962 ................... 27,136.66 1963 ................... 28,073...
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