Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' income taxes:
Medical Collection Corporation Calendar Year Deficiency 1971 ......... $56,117.63 1972 ......... 72,055.17 Robert J. Smith Calendar Year Deficiency 1971 ......... $ 3,760.68 1972 ..........
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