Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In separate notices of deficiency dated July 29, 1987, respondent determined deficiencies in petitioners' Federal income tax for 1979 and 1980 as follows:
Year Deficiency 1979 ........................ $134,641.89 1980 ........................ $ 2,990.76
Respondent has conceded the deficiency determined for 1980 with respect to...
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