Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioners' Federal income taxes as follows:
Year Deficiency 1978.................. $ 54,013.08 1979.................. 107,316.30 1980.................. 93,392.11
After concessions, the issue remaining for decision is whether the management by the petitioner E. Mauran Beals...
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