Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated September 28, 1977, respondent determined a deficiency in income taxes due from petitioners Berkeley E. and Barbara A. Grove for their taxable year ended December 31, 1973 in the amount of $236,658 plus an addition to tax under section 6653(a) in the amount of $11,832.90. By separate letter dated September 28, 1977 respondent determined a deficiency in income taxes due from petitioner...
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