Memorandum Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Docket No. Year Deficiency 9412-79 1975 ........ $1,179,048 11711-80 1976 ........ 1,355,700 1977 ........ 2,044
These cases are consolidated for purposes of trial, briefing, and opinion, and are presently before the Court on respondent's motion for partial...
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