Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1978 and 1979 in the amounts of $162,296.95 and $79,544.00, respectively. In amended answers filed in each of these consolidated cases[,] respondent increased the deficiency for each year to $323,518 for 1978 and $372,668 for 1979.
After concessions by both parties, the issues for decision are (1) the...
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