SCOTT, Judge:
Respondent determined a deficiency in the Federal income tax of petitioners Robert O. Anderson and Barbara P. Anderson for their tax year ending October 31, 1977, in the amount of $104,263, and for their tax year ending October 31, 1979, in the amount of $3,059,563. Respondent determined a deficiency in the Federal income taxes of petitioner, the Hondo Co., for its tax year ending December 31, 1979, in the amount of $1,795,673.
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