Memorandum Findings of Fact and Opinion
COHEN, Judge:
In docket No. 22752-82, respondent determined a deficiency of $19,010 in petitioner Edward J. Costello, Jr.'s income tax liability for 1978. In docket No. 33881-83, respondent determined deficiencies of $10,807 and $1,446 in the income tax liability of petitioner Johnsen, Manfredi & Thorpe, A Professional Corporation, for its fiscal years ended in February 1979 and 1980, respectively. The issue for...
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