Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Calendar Year or Date Fiscal Petitioners Year Ends Amount Billy J. Gaines and Martha C. Gaines (docket No. 8305-78) 1973 ........ $2,234.66 Lewis E. Gaines, Jr. and Jackie Gaines (docket No. 8306-78) ...
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