Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable year ended December 31, 1976 in these consolidated cases by separate notices of deficiency, each dated December 24, 1981, as follows:
Docket No. Petitioner(s) Deficiency 5571-82 Jerome S. Moss and ...
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