Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:
Taxable Year Petitioner Ending Deficiency Half Moon Fruit and Produce Company ................. 2/28/75 $26,613.00 John B. Giovannetti ....... 12/31/74 5,350.00 Ronald P. Giovannetti and Norma...
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