Memorandum Findings of Fact and Opinion
CLAPP, Judge:
In these consolidated cases, respondent determined the following deficiencies in petitioners' Federal income taxes for the taxable year 1980:
Docket No. Deficiency 14283-84 .................... $23,858.00 14284-84 .................... 31,314.00 14287-84 .................... 3,772.00 14288-84 .................... 16,882.00
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