Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes by notices of deficiency:
Docket No. Year Deficiency 10707-84 1976 .............. $ 31,489.00 1977 .............. 41,046.00 1978 .............. 80,821.00 10939-84 1977 .............. 1,580.00
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