Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Petitioners(s) Taxable Year Deficiency Joseph C. Mann .............. 1974 $26,923.52 Joseph C. Mann and Shirley V. Mann ........... 1975 197.67
These cases have been consolidated for purposes of trial, briefing, and opinion.
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