Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax for the year 1971:
Dkt. No. Petitioners Deficiency 8351-74 Richard A. and Mary J. Serbousek .......... $886.06 8368-74 James E. and Constance Ramsay ............. 963.96
These cases were consolidated for purposes of trial, briefing, and opinion...
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