Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Docket No. Year Deficiency 584-81 1975 $13,112 1976 38,151 585-81 1975 13,112 1976 38,151 586-81 1976 23,388
The issues for decision...
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