WILBUR, Judge:
Respondent has determined the following deficiencies in petitioners' Federal income taxes:
Docket No. Petitioner Taxable year ended Deficiency 7100-77 Joseph R. Bolker 12/31/72 $1,714,973 7100-77 Joseph R. Bolker 12/31/73 9,747 8379-78 Joseph R. Bolker, transferee 3/28/72 896,919
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