Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioner's income tax and by its amended answer seeks the following increased deficiencies:
Deficiency Increased Per Statutory Deficiency Per Year Notice Amended Answer 1961 ........ $14,747.69 ........ 1962 ........ 22,381.01 ...
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