Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency of $66,549.50 in the petitioners' Federal income tax for 1973. The only issue for decision is whether the Commissioner has carried his burden of proving that a consent extending the period of the statute of limitations was executed by the petitioners and by the Commissioner's delegate prior to the running of such period.
Findings of Fact
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