Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Taxable Year Ended Amount September 30, 1975 .................... $15,304.00 September 30, 1976 .................... 5,582.00 September 30, 1977 .................... 21,411.59
Due to concessions, the only issue remaining for our determination is whether...
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