Memorandum Findings of Fact and Opinion
IRWIN, Judge:
In these consolidated proceedings, respondent determined deficiencies in petitioners' Federal income taxes for the calendar year 1973 as follows:
Docket No. Petitioners Deficiency 4794-76 Herschel E. and Gloria J. Perkins ...... $4,172.60* 5032-76 Frank A. and Nicolletta E. Mercado
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