Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1977 ......... $22,031.68 1978 ......... 5,067.30
All such amounts were placed in issue by the petition herein and, in addition, petitioners claimed an overpayment of tax for the year 1977 in the amount of $6,600. After concessions, the issues...
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