SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:
Petitioner Year ended Deficiency CWT Farms, Inc .......... 9/30/75 $173.91 9/30/76 24,624.41 9/30/77 28,965.84 CWT International, Inc ... 9/30/75 37,634.40 ...
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