Memorandum Findings of Fact and Opinion
WELLS, Judge:
By statutory notices of deficiency, respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Amount 1976 .................. $36,163 1977 .................. 19,382 1978................... 12,692 1979 .................. 8,570 1980 .................. 116
In the notices of deficiency encompassing the tax...
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