Supplemental Memorandum Findings of Fact and Opinion
IRWIN, Judge:
This case is now before the Court on remand from the United States Court of Appeals for the Sixth Circuit. The case was originally before this Court as a result of petitioners' filing of a petition for redetermination of deficiencies determined by respondent in their income taxes for the years 1968, 1969, and 1970. See Wolfson v. Commissioner [Dec. 35,509(M)],
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