Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Taxable Year Deficiency 1977.............. $ 5,093.85 1978.............. 14,072.43 1979.............. 1,274.00 1980.............. 9,394.37
After concessions by the parties, the remaining issues for decision are (1) whether petitioner...
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