Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes for the taxable year 1976:
Docket No. Deficiency 12336-80 .................... $132,176.10 12337-80 .................... $ 41,673.00
The issues for decision are:
(1) Whether the transaction by which Bari Associates acquired the subject property...
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