OPINION
COHEN, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Year Deficiency 1975 ................. $2,823.78 1976 ................. 6,682.94 1977 ................. 24,304.34 1978 ................. 6,637.72
After concessions by petitioners, the issue remaining for decision in this fully stipulated...
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