Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in income tax for the taxable years 1976 through 1980 as follows:
Year Deficiency 1976 .................... $26,475.39 1977 .................... 29,163.63 1978 .................... 28,351.00 1979 .................... 36,692.00 1980 .................... 42,316.42
By amended answer respondent...
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