Memorandum Findings of Fact and Opinion
GERBER, Judge:
In a timely statutory notice of deficiency, respondent determined the following deficiencies in petitioners' income taxes:
Year Deficiency 1976 .......................... $ 2,149 1977 .......................... 7,037 1979 .......................... 49,884 1980 .......................... 66,335 1981 ...
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