Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in, and additions to, petitioners' Federal income taxes for the years 1980 and 1981.
The issues for decision are:
(1) Whether petitioners filed timely joint Federal income tax returns for the years 1980 and 1981;
(2) Whether respondent is estopped from denying that the Forms 1040 filed by petitioners for the years...
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