OPINION
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Docket No. TYE Dec. 31— Deficiency 6290-79 1975 $15,394 13865-79 1976 7,510 13865-79 1977 10,136
These cases have been consolidated for purposes of trial, briefing, and opinion.
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