Memorandum Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $494 in petitioners' Federal income tax for the year 1972. In an amendment to his answer filed on April 3, 1975, the respondent claimed an increased deficiency of $693.06, or a total deficiency of $1,187.06 for that year.
The only issue for decision is whether section 1034,
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