Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Year Deficiency 1974 ..................... $ 3,721.71 1975 ..................... 4,314.11 1976 ..................... 27,205.00 1977 ..................... 32,042.92
The parties agree that petitioners are liable for the deficiencies determined for 1974...
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