Memorandum Opinion
TANNENWALD, Chief Judge:
Respondent determined deficiencies of $2,244 in Aaron and Rachel Miller's 1976 Federal income tax, $2,323 in Harold O. and Marjorie E. Miller's 1976 Federal income tax, and $1,075 in Hubert E. and Mildred E. Miller's 1976 Federal income tax. The sole issue for decision is whether petitioners must recapture, under section 47,
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