Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in Federal income tax against petitioners as follows:
Taxable Year Ended Deficiency December 31, 1975 ................ $4,215 December 31, 1976 ................ 3,221 December 31, 1977 ................ 5,179 December 31, 1978 ................ 9,265
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