Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent determined deficiencies and petitioners have claimed overpayments in petitioners' Federal income taxes for the calendar years as follows:
Year Deficiency Overpayment 1967 ........ $134,293.94 $285,085.50 1968 ........ 95,385.45 173,986.16 1969 ........ 2,083.37 112,338.58 1970 ........ 830.39 191,432.10
Due...
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