OPINION
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Deficiency 1975 ......................... $48,591.00 1976 ......................... 31,892.82 1977 ......................... 29,844.00
In two previously docketed cases, Harold A. Abeles and Barbara Abeles v. Commissioner, docket Nos. 1372-81 and 4433-83...
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