Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined that petitioners failed to report gross income in the amount of $20,025.18 for 1963, and that petitioner Joseph Schiavone failed to report gross income of $16,229.25 and $18,715.51 for 1964 and 1965, respectively. Respondent determined the following deficiencies and fraud penalties:
Income Tax Section 6653...
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