OPINION
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax as follows:
Docket No. Taxable year Deficiency 31285-81 1977 $25,400 1978 13,767 1979 10,135 234-82 1979 21,908 27133-82 1980 29,582 5553-84 1981 11,590 34739...
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