MICHELSON v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PARKER, Judge:

In these consolidated cases, respondent determined deficiencies in petitioner's Federal income tax as follows:

                                    Amount of
  Year                              Deficiency

  1976 ............................ $ 77,996
  1977 ............................   14,121
  1978 ............................   12,049
  1979 ...................

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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