Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined the following deficiencies in petitioners' Federal income tax:
Year Deficiency 1974 .............. $ 5,679.00 1975 .............. 17,497.00 1976 .............. 7,644.00 1977 .............. 12,445.00 1978 .............. 12,216.00 1979 .............. 12,475.00
After concessions, the sole issue for decision is whether...
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