Memorandum Findings of Fact and Opinion
PAAR, Judge:
Respondent determined deficiencies of $10,095.50, $3,406.54 and $10,903.00 in petitioners' Federal income tax for the calendar years 1979, 1982 and 1983, respectively.
After concessions, the issues for decision are: (1) whether respondent's motion under Rule 41(b)(1)
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