TANNENWALD, Judge:
In these consolidated proceedings, respondent determined the following deficiencies in income tax:
Petitioners Docket No. Year Deficiency E. Keith Owens (transferee) ---------- 1947-70 1964 $103,601.41 E. Keith Owens and Sharon E. Owens --- 1988-70 1965 78,443.00
In docket No. 1947-70, the issues are (1) whether...
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