OPINION
WHITAKER, Judge:
For the years 1976 and 1977, deficiencies were determined by respondent as follows:
Against the Estate of Thomas J. Henry, Deceased1 1976 ......................... $15,701 1977 ......................... 7,938 Against Thomas J. Henry Associates, Inc. FYE Sept. 30, 1976 ................. $6,541...
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