OPINION
FAY, Judge:
Respondent determined the following deficiencies in petitioners' 1977 Federal income tax:
Docket No. Deficiency 7888-80 ............. $33,841.00 9149-80 ............. 20,771.22
These cases are consolidated for purposes of trial, briefing, and opinion. Petitioners in docket No. 9149-80 are presently before the Court on...
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