Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1976, 1977 and 1978 in the following amounts:
Taxable Year Deficiency 1976 ................ $25,660.00 1977 ................ 26,945.33 1978 ................ 15,681.01
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