Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in petitioners' Federal income tax in the following amounts for the following years:
Year Deficiency December 31, 1977 ......................... $26,960.00 December 31, 1978 ......................... 12,326.00 December 31, 1979 ......................... 27,195.00 December 31, 1980 .................
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