OPINION
KÖRNER, Judge:
In these consolidated cases, respondent determined deficiencies in Federal income tax as follows:
Docket No. Petitioner Year Deficiency 4291-82 E-B Grain Co., Inc. 1978 $130,121.37 4292-82 Kirby L. Everette 1976 82,369.92 and Dorthy G. Everette 1977 63,771.57 1978...
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