Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income tax liability as follows:
Engles Coin Shop, Inc. Year Deficiency 1973 ........... $2,455,740.06 1975 ........... 9,602.10
John R. and Linda Engle Year Deficiency 1973 ............ $ 8,263...
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