Memorandum Opinion
SWIFT, Judge:
In a timely statutory notice of deficiency dated February 13, 1984, respondent determined deficiencies in petitioners' Federal income tax liabilities, as follows:
Years Deficiencies 1979 .................... $9,185 1980 .................... 389
The sole issue for decision is the extent to which petitioner Evan W. Lumsden was at risk under section...
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