Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioners' Federal income taxes:
Petitioner Year Deficiency Joseph J. Tallal, Jr. 1977 $ 3,924.00 Joseph J. Tallal, Jr. 1978 54,435.00 Joseph J. Tallal, Jr. and 1979 44,669.00 Peggy P. Tallal
After concessions, the issues...
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