Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the years and in the amounts that follow:
Year Deficiency 1973 ....................... $ 12,100 1975 ....................... 73,790 1976 ....................... 100,755
After concessions, the issues for decision are: (1) Whether and to what extent...
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