Memorandum Findings of Fact and Opinion
SWIFT, Judge.
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1982 ................... $7,385.26 1983 ................... 6,797.37
Petitioners operated a distributorship for the Amway Corporation (Amway) that generated substantial gross income in 1982 and 1983. Respondent concedes that petitioners...
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