Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined the following deficiencies in the petitioners' income taxes:
Docket No. Petitioners Year Deficiency 3470-66 R. Abbott Sinskey and Minna Sinskey ... 1960 $67,617.20 3602-66 CorpAmerica, Inc. ... 1960 24,084.11 6534-66 R. Abbott Sinskey ... 1962 7,586.85 and Minna Sinskey ... 1963...
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