KÖRNER, Judge:
Respondent determined deficiencies in Federal income taxes against petitioners Paul J. Perlin, Henry E. Hershey, and Ellen K. Hershey (hereinafter collectively referred to as petitioners) as follows:
Petitioner(s) Docket No. TYE Dec. 31— Deficiency Paul J. Perlin 26381-82 1978 $498,1612 20634-83 ...
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