OPINION
RAUM, Judge:
The Commissioner determined deficiencies in petitioners' income tax as follows:
Petitioner Year Deficiency Norman and Marjorie Titcher------------------------------- 1964 $17,032.68 Estate of Harris B. Goldberg, Deceased, Wendy Goldberg, Administratrix, and Wendy Goldberg----------------------- 1964 34,945.30
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