Memorandum Findings of Fact and Opinion
COHEN, Judge:
By notice of deficiency dated March 20, 1981, respondent determined a deficiency of $922 in petitioners' income taxes for the year 1978. In a notice of deficiency dated May 14, 1981, respondent determined a deficiency of $1,199.71 in petitioners' income taxes for the year 1979.
Some of the facts have been stipulated and the stipulation and exhibits thereto are incorporated herein by this reference...
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