Memorandum Findings of Fact and Opinion
DAWSON, Judge:
In these consolidated cases respondent determined the following deficiencies in petitioners' Federal income taxes:
Petitioner Dkt. No. Year Amount William E. Gran .... 9794-79 1977 $2,682.72 Shirley M. Gran .... 9934-79 1977 2,043.61
Petitioners have agreed that, if the Court holds that the William E. Gran Family Equity Pure Trust should not...
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