Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in petitioners' 1980 and 1981 Federal income tax in the amounts of $4,175.00 and $3,444.00, respectively. The issues for decision are as follows:
(1) Was petitioner
(2) If so, do respondent's prior assurances to petitioner that this...
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