Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Docket Taxable Petitioner No. Year Deficiency Rex D. Horchem ...... 232-79 1976 $1,213.361 James Allen Scott ... 233-79 1976 $1,050.00
The sole issue for decision is whether petitioners' wholly...
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