OPINION
WELLS, Judge:
By statutory notices of deficiency dated June 6, 1984, respondent determined deficiencies in petitioners' income taxes for the taxable years ended December 31, 1978, and December 31, 1979, as follows:
Docket No. Petitioner Year Deficiency 31100-84 John C. Zinniel 1978 $6,552 and Gayle A. Zinniel 1979 ...
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