Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in the income tax liability of Southeastern Mail Transport, Inc. (SMT), docket No. 703-81, in the amounts for the fiscal years as follows:
Fiscal Year Ended Amount June 30, 1978 ............... $20,167.38 June 30, 1979 ............... 88,587.49
The deficiencies determined against petitioners Tony E. Davis...
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