Memorandum Findings of Fact and Opinion
CHABOT, Judge:
Respondent determined deficiencies in Federal individual income tax against petitioner Kenneth D. Christman (hereinafter sometimes referred to as "Christman") for 1979 in the amount of $1,506, and against both petitioners for 1980 in the amount of $7,434.39.
After concessions by both sides, the issues for decision
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