Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Docket No. Year Deficiency1 4346-80 (Robert L. 1975 $15,240 and Helene E. 1976 22,580 Wheeler) 1977 13,814 4347-80 (Morton S. 1975 46,424 and Beverly 1976 42,537 Rosen) ...
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