Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated August 10, 1979 respondent determined deficiencies in petitioners' income taxes for the taxable years 1971 through 1974 as follows:
Taxable year ended Dec. 31 Deficiency 1971 .............. $ 2,154 1972 .............. 6,787 1973 .............. 21,613 1974 .............. 103,692
After concessions...
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