Memorandum Opinion
WHITAKER, Judge:
By statutory notice dated September 8, 1988, respondent determined a deficiency in petitioners' Federal income tax for the years and in the amounts as follows:
Year Deficiency 1975 ................... $95,869 1976 ................... 34,515 1977 ................... 5,871 1978 ................... 1,966
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