Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioner's income tax as follows:
Taxable Docket No. Year Ended Deficiency 10981-77 ............. 6/30/73 $ 8,866 6/30/74 4,066 6/30/75 14,477 8342-78 .............. 6/30/77 15,266
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