OPINION
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years ending December 31, 1977, and December 31, 1978, of $61,924 and $63,281, respectively. In his answer, respondent asserted an increased deficiency for 1978 of $10,451. These deficiencies concern the "Nitrol issues" arising from respondent's adjustments to petitioners' Schedules C, and were the subject of a trial held before Judge Nims...
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