Memorandum Opinion
KÖRNER, Judge:
Respondent determined deficiencies of income tax for the years 1979 and 1980 against petitioners as follows:
Year Deficiency 1979 ..................... $ 1,941 1980 ..................... 1,377
The issues which we must decide are: (1) Whether petitioner Horace S. Case (hereinafter "petitioner"
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