Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
By notice of deficiency dated September 29, 1983, respondent determined deficiencies in petitioner's Federal income taxes for the fiscal years ended September 30, 1979, September 30, 1980, and September 30, 1981, in the following amounts:
FY ended Sept. 30, Deficiency 1979 .................... $16,255 1980 ......................
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