Memorandum Findings of Fact and Opinion
FEATHERSON, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes and additions to tax in the consolidated cases of Jackson B. and Susanne Bragg (docket No. 19598-84) and John E. and Caroline Kaye (docket No. 30213-84) for 1980 and 1981:
Addition ...
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