GOFFE, Judge:
The Commissioner determined a deficiency in petitioner Sherwood Properties, Inc.'s Federal income tax for the taxable year ended June 30, 1978, in the amount of $128,650.79. The Commissioner also determined a deficiency in petitioner Freedland Industries Corp.'s Federal income tax for the taxable year ended June 30, 1976, in the amount of $141,283.67.
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