OPINION
TANNENWALD, Chief Judge:
The trial of this case took place on March 2, 1981. Petitioners appeared pro se. The taxable years involved are 1976, 1977, and 1978. The only items which were placed in dispute by the pleadings, and which were the subject matter of the trial involved, were whether: (1) Certain income was taxable to petitioners or a trust (the principal issue); (2) the trust or petitioners were entitled to depreciation and an investment...
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