Memorandum Findings of Fact and Opinion
CLAPP, Judge:
In these consolidated cases, respondent determined a $12,789.09 deficiency in the 1982 Federal income tax of petitioner Douglas Mullins, and a $21,199.83 deficiency in the 1982 Federal income tax of petitioners David B. Jordan, Jr. and Joyce G. Jordan. After concessions by both parties, the sole issue is whether section 46(e)(3)(B)
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