Memorandum Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the years and the amounts as set forth below:
Petitioners Year Amount William H. Kinsey & Est. of Irene S. Kinsey, Deceased, William H. Kinsey, Executor ....................... 1977 $45,495.00 William H. Kinsey ....................... 1978 $67,254...
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