Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
In these consolidated cases the Commissioner determined deficiencies as follows:
Petitioners William L. and Kathleen B. McReavy ("the McReavys");
Sec. Sec. Deficiency 6653(a)(1)1 6653(a)(2) 1981 ........... $7,164 -- -- ...
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