Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts and for the taxable years as follows:
Taxable Year Deficiency 1978 .................. $ 368.00 1979 .................. 698.00 1980 .................. 5,519.00 1982 .................. 103,735.00 1983 .................. 10,480.48...
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